ITAT Ahmedabad allowed three appeals for statistical purposes by setting aside CIT(A) orders and directing fresh adjudication, subject to deposit of ₹5,000 per case in the PM National Relief Fund.
The Tribunal remanded the reassessment after the assessee sought another opportunity to explain the source of investment. The addition was set aside subject to payment of costs and fresh adjudication on merits.
The Tribunal deleted the ₹60 lakh addition under Section 68 after noting that the loan was received and repaid through banking channels and the lenders identity was established.
The Tribunal held that immunity from penalty requires strict compliance with statutory conditions, and absence of proof of Form 68 filing disentitles relief.
The Tribunal held that the disallowance of share purchase cost under Section 115BBE, arising from alleged bogus LTCG, is interlinked with the quantum issue.
The Tribunal upheld deletion of addition made on alleged unexplained investment in property. It held that difference between initial agreement value and final sale deed, without evidence of extra payment, cannot justify addition under Section 69.
The Tribunal ruled that invoking clause (i) instead of clauses (iii)/(iv) of Explanation 2 was legally incorrect where material belonged to another person. The reassessment proceedings were quashed for non-compliance with statutory procedure.
ITAT Ahmedabad held that property payments were properly explained with bank records and affidavits. Additions under Section 69 for cash deposit and stamp duty were deleted.
ITAT held that cash loans taken for son’s education were bona fide and supported by evidence. Reasonable cause under Section 273B justified deletion of penalty.
ITAT Ahmedabad held that appellate authorities can entertain fresh legal claims even if not made in the return of income. BSNL VRS-2019 compensation was held exempt u/s 10(10B), and rejection by CIT(A) was set aside.
