The Tribunal clarified that even where the assessee owns more than ten trucks, Section 44AE can be used as a fair yardstick for income estimation. Arbitrary assessment and multiple additions were set aside.
The Tribunal held that taxing total gross winnings without examining expenditure and loss components violates principles of fairness. The case was sent back for proper scrutiny of actual net winnings.
Where more than three years had elapsed, approval from the higher specified authority was compulsory before issuing notice. Failure to obtain such approval vitiated the reassessment proceedings.
The ruling addressed whether a delayed application could survive after statutory change. The Tribunal directed fresh consideration by applying the liberalized timeline introduced by Finance Act, 2024.
ITAT Chennai held that merely opting for Vivad-Se-Vishwas does not end an appeal unless settlement is completed; dismissal by assumption was invalid and appeal was restored for merits adjudication.
ITAT Chennai held that once delay in filing return is condoned under section 119(2)(b), CPCs denial of deduction under section 80P collapses and relief must be granted.
The tribunal held that a purchase cannot be treated as bogus solely based on third-party allegations. Without independent verification by the Assessing Officer, the disallowance was held unsustainable.
The tribunal held that interest earned from deposits with co-operative banks qualifies for deduction under Section 80P(2)(d). Such banks are treated as co-operative societies, making the interest fully deductible.
The tribunal held that amounts already disclosed and taxed as accommodated receipts cannot be taxed again under another head. Separate additions were deleted as they resulted in impermissible double taxation.
The tribunal held that interest earned on savings bank deposits is attributable to the business of providing credit to members. Such incidental bank interest qualifies for full deduction under Section 80P(2)(a)(i).
