The Tribunal ruled that mere observations about cash transactions are insufficient to levy penalty under Section 271D. A specific finding establishing contravention of Section 269SS is mandatory before imposing penalty.
The Tribunal held that entries found in third-party ERP software during a search cannot alone justify unexplained investment additions under Section 69. Absence of corroborative evidence led to deletion of the entire addition.
The Tribunal held that reassessment proceedings were invalid where the Assessing Officer ignored the assessees detailed response and documentary evidence. ITAT ruled that such action violated principles of natural justice and reflected non-application of mind.
Ahmedabad ITAT held that the Assessing Officer wrongly treated entire business liabilities and receipts as unexplained income. The addition was drastically reduced to estimated profit at 15% of disputed turnover.
The Tribunal held that once the income disclosed in the return filed under Section 148 was accepted without any addition, there could be no allegation of under-reporting or misreporting. The entire penalty of ₹4.91 lakh was deleted.
The Tribunal ruled that corpus donations cannot be taxed merely because Section 12AA registration was granted subsequently. Once registration existed before processing of return, exemption under Section 11 could not be denied.
The Tribunal held that agricultural land situated beyond notified municipal limits is not a capital asset under the Income Tax Act. It deleted the entire capital gains addition arising from sale of such land.
The Tribunal held that amount received on surrender of a pension policy could not be taxed as Income from Other Sources without proper examination of Section 80CCC(2). The entire addition of ₹10.40 lakh was deleted.
ITAT Ahmedabad held that no unexplained investment addition could survive where the booked property deal was cancelled and funds were refunded. The ruling emphasized verification of actual payment flow and subsequent cancellation events.
The Tribunal held that capital introduced in a partnership firm cannot be treated as unexplained merely on suspicion when confirmations, bank statements, and source details are available. The entire addition of ₹29 lakh under Section 69A was deleted.
