ITAT Ahmedabad held that property payments were properly explained with bank records and affidavits. Additions under Section 69 for cash deposit and stamp duty were deleted.
ITAT held that cash loans taken for son’s education were bona fide and supported by evidence. Reasonable cause under Section 273B justified deletion of penalty.
ITAT Ahmedabad held that appellate authorities can entertain fresh legal claims even if not made in the return of income. BSNL VRS-2019 compensation was held exempt u/s 10(10B), and rejection by CIT(A) was set aside.
Tribunal upheld deletion of unsecured loan addition after finding identity, creditworthiness, and genuineness established through PAN, ITRs, bank statements, and TDS records.
The Tribunal noted that the AO reopened the case under the mistaken belief that no scrutiny assessment had been made. Such factual error and absence of new incriminating material vitiated the assumption of jurisdiction under Section 147.
The Tribunal emphasized that assumptions based on common names cannot justify major tax additions. Without documentary linkage or banking trail confirmation, the Revenue’s case could not stand.
The case involved alleged bogus job-work transactions linked to a third party. The Tribunal found the receipts were genuine business income duly audited and taxed, leading to deletion of additions.
The Tribunal ruled that Section 263 cannot be invoked merely because the Commissioner holds a different opinion. Once adequate inquiry is conducted and a reasonable view is taken, revision is unsustainable.
Once the Tribunal ruled that foreign salary was not taxable in India, consequential additions for alleged unexplained investments and deposits were also deleted. The appeal was allowed in full.
The Tribunal emphasized that substantive justice prevails over technical PAN mismatch. Since income of the deceased was offered and accepted, TDS credit had to be allowed to the legal heir.
