ITAT Ahmedabad held that reopening of assessment under section 147 of the Income Tax Act is unsustainable as prerequisite laid down in law for reopening of the case beyond four years is not found to be fulfilled.
ITAT Ahmedabad held that unsecured loan taken at higher rate for commercial expediency is admissible under section 57(iii) of the Income Tax Act.
ITAT Ahmedabad held that revisional power under section 263 of the Income Tax Act correctly invoked as AO failed to examine the issue of purchase of land in the light of provisions of section 56(2)(vii)(b) of the Income Tax Act.
assessee has filed the return of income belatedly for the year under consideration but there is no prohibition to adjust the brought forward losses against the income declared belatedly in the return of income under the provision of section 139(3) of the Act.
ITAT noted that tax consultant of assessee has not followed all tax demands and necessary submissions made to Revenue Authorities during pre-covid period i.e. 06.08.2019 to 14.03.2020.
Merely the parties agreed to not to charge/pay interest on loan will not vitiate the genuineness of such loan transaction unless and until the revenue brought some cogent material on record to prove that such transaction of loan is not genuine.
Provision of Section 80P(2)(d) of the Act does not make any distinction in regard to source of the investment because this Section envisages deduction in respect of any income derived by co-operative society from any investment with a co-operative society.
CIT(A) was not right in levying interest under Section 234A of the Act when the return was filed under Section 148 itself and therefore, the interest should be charged from the date of notice under Section 148 of the Act itself and not from the date of return filed under Section 139 or it is due date under Section 139.
ITO Vs Rajesh Kumar Chhanalal Patel (ITAT Ahmedabad) Ahmedabad ITAT upholds CIT(A) order deleting the addition of Rs. 86.75 Cr under Section 69A as Assessee’s unexplained income; Holds that the cash deposited in bank account cannot be treated as unexplained as the Revenue himself in the remand report and on verification accepted that the entire […]
ITAT Ahmedabad held that addition towards closing cash balance as unexplained cash credit u/s 68 unsustained as cash was generated from agricultural activity and revenue failed to discharge the onus of disproving the said contention of the assessee.
