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.
The tribunal held that taxing entire gross receipts is unsustainable and only profit embedded in receipts should be taxed. However, the matter was remanded as fresh evidence was admitted without giving the AO an opportunity to verify.
The case involved denial of deduction on interest earned from cooperative bank deposits. The Tribunal held that such income qualifies for deduction as it is derived from investments with a cooperative society.
The AO recorded reasons for escapement without receiving confirmation from the Sub-Registrar. ITAT ruled that absence of tangible evidence vitiated reassessment, making the subsequent Section 263 revision unsustainable.
The ruling emphasized that tax authorities must gather evidence instead of relying on coerced admissions. Additions made purely on surrender statements were struck down for violating CBDT guidelines.
ITAT held that entire purchases cannot be disallowed when sales and stock are accepted. The addition was rightly restricted to 25% to cover possible inflation.
ITAT Amritsar upheld rejection of 12AB registration after finding that only ₹2.51 lakhs out of ₹40 lakhs received was spent on charitable activities. The Tribunal held that minimal charity expenditure and dominant non-charitable spending justified denial of registration.
