The ITAT Ahmedabad held that confirmations and banking documents alone were insufficient to establish genuine unsecured loans. The addition under Section 68 and related interest disallowance were upheld.
ITAT Ahmedabad held that a taxpayer cannot avoid responsibility for earlier failures to respond merely because the final notice was sent to a different email address. However, the matter was remanded for fresh consideration on merits.
ITAT Ahmedabad upheld reassessment proceedings after finding that seized diaries recorded unaccounted cash transactions exceeding prescribed limits. The Tribunal held that statutory conditions for reopening were satisfied.
The Tribunal upheld the denial of deduction under Section 80GGC after finding that the political donation formed part of an alleged accommodation entry arrangement. The ruling emphasised that deductions may be denied where investigative findings indicate a lack of genuineness and remain unrebutted by the taxpayer.
The ITAT Ahmedabad held that isolated WhatsApp messages and electronic communications cannot, by themselves, support additions in search assessments. The Tribunal deleted several additions because no corroborative evidence established actual cash transactions. The ruling underscores that suspicion cannot replace proof in tax proceedings.
ITAT Ahmedabad held that penalty under Section 43 of the Black Money Act could not be imposed when foreign assets were subsequently disclosed in returns filed under Section 153A. The Tribunal relied on the principle that such returns substitute the original returns.
The Tribunal ruled that the Revenue cannot assess the full transaction value in the hands of a confirming party absent proof of beneficial ownership. The decision underscores the importance of establishing actual receipt of consideration.
ITAT deleted the addition after finding that neither possession nor ownership had passed during the relevant assessment year. The decision emphasizes that actual transfer, not mere intention to sell, determines taxability.
ITAT held that proving the mode of payment is not enough to secure deduction for political contributions where evidence points to a bogus donation scheme. Taxpayers must establish the authenticity of the entire transaction.
The ITAT Ahmedabad held that proportionate interest disallowance cannot be sustained without establishing a direct nexus between borrowed funds and interest-free advances. The Tribunal deleted the addition as the assessee had sufficient own funds.
