Tribunal held that Section 54F allows exemption only for one residential unit. The assessee’s claim for a second flat was rejected, affirming that multiple units do not qualify unless treated as a single house.
The Tribunal held the reassessment invalid as NFAC completed the process without issuing a mandatory notice under section 148A. It ruled that an assessment is void when the jurisdictional notice is issued by one authority but finalized by another.
The Tribunal ruled that the AO’s imposition of ₹30,000 was contrary to Section 272A(1)(d), which permits only ₹10,000 per statutory default. As only one true default existed, the excess penalty was deleted. Key takeaway: penalty must be grounded strictly in statutory authority, not administrative repetition.
The Tribunal held that penalty under section 270A could not stand because the JPACK ledger titled “SABARI” was not proven to belong to the assessee. The ruling emphasises lack of corroborative evidence and inconsistencies in the seized material.
ITAT Chennai struck down a protective addition of ₹14.91 Cr made u/s 69, citing invalid u/s 153C jurisdiction. No substantive assessment existed in the companies’ hands for AY 2014-15, reinforcing that protective additions require year-wise satisfaction and corroborative evidence.
Tribunal confirmed that powers to question “source of source” under section 68 exist only from 01-04-2023. Additions on unsecured loans and student deposits were deleted, while TDS disallowance was remanded.
ITAT Chennai ruled that for captive power consumption, the market value for Section 80-IA deduction should be the rate at which electricity is supplied to industrial consumers, not the SEB purchase rate. AO’s downward adjustment was deleted.
ITAT held that most jewellery seized during a search could be accounted for from declared drawings and past income, reducing addition to ₹72.45 lakh. Ruling emphasizes that unexplained investment must be proven in relevant assessment year.
ITAT held that post-29.03.2022, notices must be issued faceless; issuance by JAO violated law, invalidating the reopening and assessment.
The Tribunal held that Section 87A contains no exclusion for long-term capital gains and allowed the rebate since total income remained below Rs.5 lakhs. The order of the lower authorities was set aside.
