ITAT Agra held that the assessee is entitled to claim deduction u/s. 10A of the Income Tax Act before setting off carry forward losses and unabsorbed depreciation. Accordingly, appeal of the assessee succeeds on this ground.
ITAT held that scrap trading does not follow a fixed sales pattern and income declared under Section 44AD cannot be rejected on suspicion. Addition under Section 68 was deleted.
The Tribunal upheld deletion of ₹3.67 crore added as unexplained cash credit from Singapore art exhibition sales. It held that detailed export, remittance, and bank evidence fully established the genuineness and source of funds.
The dispute examined whether loan interest used to buy virtual digital assets could be deducted. The ruling held that such interest forms part of cost of acquisition and is allowable despite Section 115BBH restrictions.
The ITAT ruled that unexplained cash can only be assessed in the year in which it is seized. An addition made in an incorrect assessment year is legally unsustainable and must be deleted.
Unexplained cash deposits and rent discrepancies led to rejection of books under section 145(3). However, the Tribunal held that estimating profits at 1% was excessive and moderated it to 0.50%.
The tax authorities disallowed Bhandara expenses assuming a religious character without concrete evidence. The Tribunal held that mere suspicion cannot override the accepted fact of food being provided to the needy.
The Tribunal held that reassessment under section 147 fails when the alleged income escapement cited for reopening is accepted and no related addition is made. Without sustaining the original reason for reopening, jurisdiction itself collapses.
The Tribunal held that denial of TDS credit solely on mismatch grounds requires factual verification. The Assessing Officer must examine whether the individuals in whose names TDS was deducted have already claimed the credit.
The Tribunal held that reassessment notices issued by the Jurisdictional AO after the faceless regime came into force are invalid. The key takeaway is that only faceless authorities can initiate reassessment post-29 March 2022.
