The Tribunal ruled that when no new loans are borrowed or granted, taxpayers need not re-prove nexus annually. Interest paid deduction under section 57(iii) was restored.
ITAT Agra restored AO’s 145(3) rejection and additions under sections 68 & 41(1) for re-verification, directing assessee to produce complete books and supporting documents. The matter requires factual verification to ensure substantial justice.
The Tribunal held that arrears of a deceased employee must be taxed only in the legal heir’s representative capacity. The assessment made solely in individual capacity was deleted.
The addition was based on a loose paper that did not match Yes Bank loan details or HMA ledger figures. The Tribunal upheld that such uncorroborated papers cannot sustain a 69C addition, especially when business had not yet commenced. The takeaway is that tax additions must be backed by verifiable evidence, not estimations on loose sheets.
ITAT Agra held that purchases made by a tenant cannot be attributed to the landlord, deleting ₹2.50 crore addition for alleged bogus meat purchases, emphasizing factual accuracy in assessments.
The issue involved a common sanction letter covering multiple assessees and years, issued on the same day the AO sought approval. ITAT found this composite approval inconsistent with judicial mandates requiring individualized scrutiny. As a result, the assessment was declared void ab initio, making all additions infructuous.
ITAT held that a penalty under Section 271(1)(c) is invalid when concealment and inaccurate particulars are invoked together without specifying the exact charge. The ruling reinforces that penalty notices must be unambiguous and legally precise.
The Tribunal emphasized that statutory obligations under Section 250(6) cannot be bypassed even when the assessee defaults in appearance. Lack of reasoning and non-discussion of issues rendered the NFAC’s ex-parte order unsustainable.
ITAT rules that assessments under section 144 without proper section 148 notice are void when returns are filed late, affirming taxpayer procedural rights.
ITAT found that reopening relied on wrong bank deposits, incorrect assessee details, and a mechanical sanction under section 151. The reassessment under sections 144/147 and the ₹15 lakh unexplained cash addition were deleted.
