The Tribunal ruled that under-reported income must be calculated as the difference between assessed income and income processed under Section 143(1)(a). Penalty computation was sent back for recomputation due to incorrect methodology adopted by the AO.
The ITAT Ahmedabad restored reassessment proceedings after the assessee produced documents showing disputed property sales and pending civil litigation. The Tribunal held that additions relating to capital gains required fresh examination where sale transactions themselves were contested.
The ITAT Ahmedabad held that co-operative banks qualify as co-operative societies for purposes of Section 80P(2)(d). The Tribunal allowed deduction on interest income earned from deposits with co-operative banks following Gujarat High Court rulings.
ITAT Ahmedabad held that delivery-based share transactions shown as investments in books could not be treated as business income without supporting evidence. The Tribunal upheld capital gains treatment for both STCG and LTCG.
The Ahmedabad ITAT held that goodwill arising from a High Court-approved amalgamation qualified as an intangible asset eligible for depreciation under Section 32(1)(ii). The Tribunal followed earlier decisions in the assessee’s own case.
ITAT Ahmedabad held that reassessment based solely on search material seized from a third party must be initiated under Section 153C and not Sections 147/148. The Tribunal quashed the reassessment for lack of jurisdiction and absence of a mandatory satisfaction note.
ITAT Ahmedabad held that depreciation on goodwill arising from amalgamation was allowable for assessment years prior to AY 2021-22. The Tribunal ruled that amendments excluding goodwill from depreciable assets operate prospectively.
The Tribunal held that mere disallowance of deduction claimed under Section 80GGC does not automatically amount to misreporting of income. It deleted the penalty as there was no evidence of false particulars or fabricated documents.
The Tribunal held that the enhanced exemption limit of ₹25 lakh under CBDT Notification No. 31/2023 applies to leave encashment claims under Section 10(10AA)(ii). Full exemption of ₹10.15 lakh was allowed to the retired SBI employee.
The Tribunal ruled that a clerical mistake in quoting TAN cannot result in denial of TDS credit when Form 16 and Form 26AS clearly establish tax deduction. The decision emphasizes substance over procedural technicalities.
