ITAT Ahmedabad upheld ₹59.9 lakh addition from demonetisation-period cash deposits and GP estimation, confirming the rejection of unverifiable books due to abnormal sales and fraudulent stock.
ITAT Ahmedabad ruled that detailed stock, sales, VAT, and bank records satisfactorily explained cash deposits of ₹2.07 crore, overturning additions made by AO and CIT(A).
ITAT Ahmedabad held that donations linked to milk supply were compulsory and cannot be treated as corpus contributions under Section 11(1)(d). The trust’s claim for exemption was denied, though a statutory deduction of 15% on revenue was allowed.
The tribunal ruled that funds donated to certain political parties were routed back to the donor, lacking genuineness. Deductions under Section 80GGC were disallowed as a result.
Addition of Rs. 2.82 lakh for deemed rent was maintained due to lack of credible evidence from the assessee. Loan interest is to be reconsidered after proper document submission.
The Tribunal held that reopening under Section 147 was legally sound and unaffected by arguments based on 153C or Notification 18/2022. Still, it directed a full rehearing because the appellate authority issued non-speaking orders without examining the merits.
ITAT Ahmedabad rules that a charitable trust’s exemption under Sections 11 and 12 cannot be denied due to a technical mismatch in reporting new 12AB registration in the ITR. The substantive validity of the original 12A registration ensures continuity of exemption.
Additions based on decoded entries from a third-party cash book were struck down, as they did not align with the assessee’s audited books or bank statements, reinforcing the ‘dumb document’ principle.
The Tribunal ruled that interest could not be disallowed when ample interest-free funds existed and no link was shown between overdraft borrowings and partners’ drawings. The key takeaway is that presumption of utilisation of own funds applies when mixed funds are available.
ITAT Ahmedabad rules routine cash deposits of small traders cannot be treated as unexplained income under Section 69A, even if no return is filed.
