The tribunal held that penalty under section 271(1)(c) cannot be levied where income admitted during survey is duly declared in the return and accepted in assessment. The key takeaway is that absence of concealment or inaccurate particulars bars penalty, even if disclosure arose from a survey.
The Tribunal applied common sense to accept that some jewellery belonged to visiting relatives. It granted partial deletion, stressing that complete relief requires corroborative evidence.
he revision targeted 80G deduction and interest under TDS/TCS provisions. The Tribunal found that the Assessing Officer had examined both issues and no prejudice was shown.
The issue was whether an extraordinary delay caused by non-communication of intimation and a CPC error could be condoned. ITAT held the delay was unintentional, imposed costs, and remanded the case for adjudication on merits.
The Revenue argued that routing through banking channels was insufficient. The Tribunal rejected this contention, holding that complete documentary evidence satisfied all requirements of Section 68.
The ruling reiterates that reassessment cannot be sustained where documentary evidence shows no loan transaction. Incorrect third-party information cannot justify reopening.
The issue was whether CPC could disallow Section 80P deduction while processing the return under Section 143(1). The Tribunal held that CPC lacked such power for AY 2019-20 as the enabling amendment came later.
The Assessing Officer imposed penalty after treating disclosed capital gains as business income. The Tribunal ruled that classification disputes, without suppression of facts, cannot justify penalty.
The issue was whether reassessment based on identical, template reasons was valid. The Tribunal held that reopening without independent application of mind amounts to borrowed satisfaction and is invalid in law.
The Tribunal upheld deletion of a ₹2.27 crore addition after finding that the capital deposit did not pertain to the assessment year in question. Without a year-wise nexus, section 68 could not be invoked.
