ITAT held that an Assessing Officer cannot substitute the DCF method chosen under Rule 11UA with the NAV method without legal justification.
ITAT held that penalty under Section 271D cannot survive where the Assessing Officer failed to record satisfaction in the assessment order.
The Amritsar ITAT held that reassessment proceedings were invalid where the officer completing the assessment had not issued the notice under Section 148. The reassessment order was quashed on jurisdictional grounds.
ITAT Amritsar held that reassessment proceedings were invalid because the reopening was based on factually incorrect AIR information. The Tribunal ruled that failure to verify bank records before issuing notice showed non-application of mind.
The Tribunal found that the reasons recorded for reopening contained incorrect figures and unsupported assumptions. It held that the reassessment proceedings were invalid and void ab initio due to lack of proper application of mind.
The Tribunal held that documents relating to the assessee were found during the search of another person. It ruled that proceedings could only be initiated under Section 153C, making the reassessment under Section 148 invalid.
The ITAT Amritsar held that a valuation report by itself cannot justify addition under Section 69 without evidence of extra payment. The Tribunal deleted the addition after finding no proof of on-money beyond the registered sale deed value.
The Tribunal held that leasehold rights transferred with land and building fall within the ambit of Section 50C. The matter relating to reassessment validity was sent back for fresh adjudication.
The ITAT Amritsar reduced additions on unexplained cash deposits after considering that the assessee and his wife were senior citizens with no regular income source. The Tribunal allowed part of the deposits as past savings and household cash availability.
The ITAT Amritsar remanded a case involving denial of section 54B exemption where the assessee relied on Girdawari records to prove agricultural use of land. The Tribunal directed fresh verification of land records after finding disputes regarding cultivation entries in revenue documents.
