The ITAT concluded that non-compliance with faceless procedure under Section 151A renders Section 148 notices invalid, nullifying both substantive and protective additions.
ITAT Chandigarh deleted ₹38.70 Lakh addition as unexplained expenditure, holding that fully bank-routed agricultural expenses cannot be disallowed merely due to missing bills. The Tribunal confirmed that legitimate orchard expenses on labor, fertilizers, and packing are deductible from agricultural income.
Tribunal directs AO to apply the 30% tax rate on unexplained cash deposits during Nov–Dec 2016, citing Madras High Court ruling, partially allowing assessee’s appeal.
The Tribunal held that only the first non-compliance under Section 142(1) could attract penalty, deleting the remaining ₹50,000 imposed for repeated defaults. It also restored penalties under Sections 271A and 271(1)(c) for fresh adjudication since they depend on the pending quantum appeal.
ITAT held that Section 69 cannot apply when the assessee is not proved to own the cash. Unrebutted affidavits established the source, and mere suspicion cannot justify an addition.
Tribunal held that a reassessment cannot be triggered solely on another person’s search statement. With no evidence against the assessee, the 147 proceedings and bogus-purchase addition were struck down.
The Tribunal upheld CIT(A)’s order, confirming deletion of additions related to unexplained creditors, GST, bogus purchases, and purchase differences. Proper reconciliation and supporting documents established genuineness, highlighting the importance of maintaining accurate records.
Receipt and repayment of Rs. 2.02 crore via proper banking channels establishes genuineness of the transaction; Section 68 addition was deleted despite non-materialisation of business.
ITAT Chandigarh ruled that income and valuation additions based solely on third-party digital data or statements cannot be made without corroboration from the assessee’s records, leading to deletion of disputed amounts.
ITAT allowed the appeal for statistical purposes, citing genuine non-receipt of the order by the assessee and restored the matter for reconsideration.
