The AO added expenditure based solely on a mistaken audit report entry. The ITAT deleted the addition after confirming from the concerned party that no transaction occurred.
The Tribunal held that statutory jurisdiction must be strictly followed in income-tax proceedings. In absence of proof of transfer to the assessing ward, the assessment was declared invalid and set aside.
The Tribunal held that interest income arising from working capital used in regular activities retains its character as business income. Section 80P relief cannot be denied merely because income arises as bank interest.
The Tribunal held that amounts reflected in regular books and disclosed in returns before search cannot be treated as unexplained expenditure. Section 69C was found inapplicable as no out-of-books spending was established.
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.
