The Tribunal sustained reassessment based on search information but faulted the disallowance of political donations. The key takeaway is that additions cannot rest solely on untested third-party statements without cross-examination.
The Tribunal held that a continuously maintained ledger found during search constituted reliable evidence. Additions for unexplained expenditure under section 69C were sustained based on corroborated diary entries.
The Tribunal held that once a Section 263 revision is set aside, the consequential assessment has no legal existence. All proceedings based on such assessment automatically collapse.
The Tribunal held that when stamp duty value is disputed, the Assessing Officer must refer the matter to the DVO. Fair market value determination is mandatory before sustaining a Section 50C addition.
Authorities found the land had been sold decades earlier and the MOU acknowledged no possession or rights. The Tribunal affirmed taxation under section 56. The ruling clarifies that an MOU cannot convert non-rights into capital receipts.
The Tribunal held that a general survey admission by the seller cannot justify additions in every buyers case. Documentary proof of purchases and sales outweighed unsupported allegations.
ITAT Ahmedabad held that the assessee is entitled to the benefit of indexed cost of acquisition while computing book profit under section 115JB of the Income Tax Act. Accordingly, AO directed to recompute book profit after allowing indexation.
The Tribunal held that reassessment beyond three years is invalid where the alleged escaped income is below ₹50 lakh. A notice issued for a ₹5 lakh donation was declared void ab initio.
The Tribunal held that reopening based solely on Insight Portal inputs without independent application of mind is invalid. Since the reassessment itself failed, the addition of share LTCG as unexplained income under section 68 could not survive.
Additions were deleted after finding that the Revenue relied on presumptions rather than tangible proof. The decision reinforces that the burden to prove undisclosed income lies on the tax authorities.
