Though some estimation was justified after rejection of books, a flat 1% rate was found arbitrary. The ITAT reduced the estimate to 0.50% aligned with prior years’ margins.
Cash deposited during demonetisation was explained as coming from income surrendered and accepted in an earlier survey. The Tribunal held that disbelief about holding cash cannot replace evidence and deleted the section 69A addition.
The ITAT held that additional evidence filed under Rule 46A cannot be brushed aside without examination. Since the documents were vital to Section 68 requirements, the matter was remanded for fresh adjudication.
ITAT held that disclosures in an election affidavit cannot, by themselves, justify reopening an assessment. The ruling reinforces that reassessment requires fresh tangible material and a live link to income escaping assessment.
Tribunal holds that leave encashment is fully exempt as the updated CBDT limit of ₹25 lakh applies. The rectification restricting exemption to ₹3 lakh was set aside.
ITAT held that mass same-day approval without reviewing records violated Section 153D. The ruling confirms that mechanical approvals invalidate 153A assessments.
The Tribunal held that AO’s ad-hoc disallowances were unsustainable as he failed to verify evidence. CIT(A) examined detailed ledgers and explanations, deleting unsupported additions. The appeal highlights the importance of evidence-based assessments over arbitrary estimates.
ITAT Agra held that reassessment under Section 144 by JAO is valid even though faceless procedure under Section 144B was generally applicable. The CBDT Circular of 17.03.2022 provided relaxation for cases with expiring limitation. CIT(A)’s non-est finding was set aside, ensuring compliance with procedural exceptions.
ITAT Agra held that additional evidence proving the land’s distance from municipal limits is crucial for reassessment under Section 56(2)(vii). The case was remanded to AO for de novo verification, allowing the assessee to file further supporting documents.
The Tribunal found that the AO failed to establish any bogus purchase or sale since the assessee never handled the goods and only received net surplus. Identical findings in earlier years compelled the ITAT to delete the same addition again. The takeaway is that established business patterns cannot be arbitrarily recharacterized as accommodation entries.
