The ITAT ruled the reassessment void because the AO failed to verify Insight data against the taxpayer’s filed return, leading to a factual mismatch and generic reasons for reopening. The decision confirms that mechanical satisfaction based on unverified information lacks the “live link” required for a valid Section 147 jurisdiction.
The ITAT Ahmedabad confirmed additions totaling over ₹4.78 crore for unexplained partners’ capital and unsecured loans. The Tribunal ruled that the firm failed to discharge its onus under Section 68 by relying on unaudited and unsubstantiated documents.
The ITAT Ahmedabad set aside the CIT(E)s order rejecting 80G approval, ruling that the mere presence of religious objects does not automatically disqualify a charitable trust. The CIT(E) must now verify if the trust’s actual religious expenditure exceeds the 5% threshold under Section 80G(5B) before denial.
This ITAT Ahmedabad decision rules that the Centralised Processing Centre (CPC) cannot summarily reject a new manufacturing company’s claim for the 22% tax rate under section 115BAB during processing under section 143(1) without issuing a prior intimation. The Tribunal held that the eligibility for the concessional rate is a debatable issue that cannot be adjusted as a “mistake apparent from record.”
The PCIT challenged the assessment order under Section 263 over the AO’s acceptance of goodwill depreciation, warranty provision, and CSR-linked 80G deduction. The ITAT quashed the revision, finding the AO conducted due inquiry and adopted a plausible legal view on all three claims. The ruling confirms that an assessment order based on due inquiry cannot be revised merely on a difference of opinion.
ITAT quashes an income tax addition for cash deposits, ruling that a detailed documentary trail explaining the source for visa purposes cannot be dismissed solely by a third party’s denial.
The Ahmedabad ITAT has struck down reassessment orders against Arpanbhai Virambhai Desai, holding that the AO’s reliance solely on an ACB disproportionate assets report without independent application of mind or specifying escaped income is “borrowed satisfaction,” invalidating the Section 147 jurisdiction.
ITAT Ahmedabad held that unexplained credit additions cannot be sustained where HUF’s bank transactions are fully documented, and reassessment beyond four years without failure to disclose material facts is invalid.
The ITAT Ahmedabad rules that an assessment framed on a dissolved firm is not automatically void if the Assessing Officer (AO) was not notified of the dissolution. The case, Krishna Enterprise Vs ITO, involved a firm dissolved in 2016, a subsequent ex-parte assessment, and issues of non-compliance and alleged double taxation, leading to the matter being restored for re-adjudication.
The ITAT confirmed that the stamp duty value on the agreement date should be used for tax calculation, not the registration date, when part consideration is paid electronically beforehand.
