ITAT held reassessment invalid as it was initiated merely on Insight Portal data and third-party statements without verification or application of mind.
The issue was whether year-old cash withdrawals could explain demonetisation-era deposits. ITAT held that absence of a direct nexus and contrary bank entries justified addition under section 69A.
The Tribunal quashed reassessment where the Assessing Officer invoked section 147 without examining books of account or correlating bank deposits with returned income.
The Tribunal upheld addition of demonetisation cash deposits after rejecting the claim that funds came from old cash withdrawals. Mere assertion of past withdrawals, without evidence of cash retention, was held insufficient.
The Tribunal found the appellate order mechanical where Rule 46A evidence was filed but not examined. The matter was sent back for fresh adjudication after proper verification.
The issue was whether reassessment notices issued after April 2021 were valid. The Tribunal held that notices issued beyond the surviving time limit were barred, rendering all reassessment proceedings void.
The assessee sought relief citing internal lapses and adviser dependence. The Tribunal ruled that consistent audits and filings undermined claims of ignorance. Long delays require specific, convincing justification, which was absent.
The PCIT sought to revisit claims already scrutinized and partly disallowed. The Tribunal ruled this to be a change of opinion and invalid. Revision demands clear error and prejudice, not reappraisal.
Accepting the assessee’s explanation for delay and non-appearance, the Tribunal condoned the delay and set aside both lower orders. The AO was directed to re-decide the issue of cash deposits after proper hearing.
The issue was whether penalties under sections 271D and 271E apply to cash dealings of a credit society with its members. ITAT held that genuine, audited member transactions supported by reasonable cause are protected under section 273B.
