The tribunal held that disallowance under Section 14A cannot be made when the assessee has not earned any exempt income during the relevant year. The ruling reaffirmed that the provision applies only when exempt income actually arises.
The Tribunal held that failure to consider additional evidence submitted during appellate proceedings violates principles of natural justice. The matter was remanded to the Assessing Officer for verification and fresh adjudication.
The Tribunal upheld deletion of a Section 14A disallowance after noting that the taxpayer did not earn any exempt income in the relevant assessment year. The ruling reiterates that Section 14A cannot be invoked in the absence of exempt income.
The Tribunal ruled that simultaneous proceedings arising from reassessment and revision for the same year could lead to multiplicity of proceedings and inconsistent findings. It restored the entire matter to the Assessing Officer for consolidated de-novo adjudication.
The ITAT relied on surrounding circumstances, documentary evidence, and the principle of human probabilities to conclude that cash consideration was paid in a land transaction. The Tribunal confirmed the addition of unaccounted sale consideration as short-term capital gains.
ITAT Ahmedabad held that an unsigned Excel sheet found during survey, without corroborative evidence, cannot justify addition for alleged cash payments.
The Tribunal held that notices issued on or after 01.04.2021 for A.Y. 2015-16 were invalid in view of the Supreme Court’s ruling in Rajeev Bansal. As the reopening was barred by limitation, the reassessment order was quashed.
The Tribunal held that mere acceptance of demonetized currency during the demonetization period cannot justify addition under Section 68 when identity, genuineness, and source are established. Revenue’s appeal was dismissed.
The Tribunal held that rejection of 80G approval solely on religious objects was insufficient without examining whether religious expenditure exceeded 5% of total income. The matter was remanded for fresh consideration under Section 80G(5B).
The Tribunal held that once loan transactions are routed through banking channels and identity and genuineness are established, the assessee cannot be asked to prove the source of the source. The unsecured loan addition of Rs. 60 lakh was deleted.
