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.
The issue was dismissal of appeals for non-payment of admitted tax without hearing on merits. The Tribunal restored the appeals, holding that the assessee deserved an opportunity to explain advance tax liability.
The Tribunal held that when no other income source exists, bank deposits linked to business cannot be taxed separately. Estimation must reflect commercial realities of the trade.
The case involved rejection of cash deposits due to alleged improbability of holding cash. The Tribunal ruled that presumptions cannot override a registered sale deed and disclosed capital gains.
The issue was whether the appellate authority could bypass jurisdictional objections by remanding the case. The tribunal held that legal grounds striking at jurisdiction must be adjudicated first.
