The ITAT confirmed that Section 54F capital gains exemption covers the entire investment in a new residential house, including the cost of land, even if purchased early. It ruled that land is an inseparable component, upholding the construction timeline as sufficient compliance.
The ITAT upheld the disallowance of delayed employee contributions to PF/ESIC, ruling that the Supreme Courts Checkmate Services judgment is retrospective unless explicitly stated otherwise by the SC itself. The Tribunal confirmed that the doctrine of prospective overruling cannot be invoked by the assessee, as the ruling merely interprets the law as it always existed.
The ITAT ruled that interest on enhanced compensation for the compulsory acquisition of agricultural land is fully exempt from income tax, citing Section 96 of the RFCTLARR Act, 2013. The Tribunal held that this special law overrides the general tax provisions (Sections 56 and 145A), deleting the entire Rs.97.44 lakh addition.
The ruling establishes that the AO cannot selectively accept total sales and profit figures while disbelieving a corresponding cash deposit from those sales without rejecting the books or providing concrete proof of bogus entries. Treating the recorded cash deposits as unexplained income is illegal double taxation.
he ITAT restricted a S.69A addition on ₹1 crore cash deposits, ruling that treating the entire gross receipt as unexplained income was unjustified for a commission agent. Considering the low-margin onion trading business and past assessments, the Tribunal estimated 4% of the deposits as the correct taxable commission income.
The ITAT Chennai rejected the Revenue’s appeals for AY 2015-16 to 2017-18, confirming that the CIT(A)’s instruction to the AO to recompute the u/s 271AAB penalty based on a reduced quantum income (per ITAT’s prior order) is a valid corrective measure and does not violate u/s 251 appellate powers against setting aside penalty orders.
The ITAT Chennai upheld the quashing of a reassessment for AY 2017-18, ruling the u/s 148 notice invalid. As more than three years had elapsed, u/s 151(ii) required sanction from the Principal Chief Commissioner (Pr.CCIT), not the Principal Commissioner (Pr.CIT), confirming the jurisdictional defect.
ITAT Chennai sustains 50% disallowance of claimed agricultural income (Padam Kumar Vs DCIT). Holds land ownership alone doesn’t prove cultivation; evidence is necessary.
ITAT Chennai deletes Rs.1.86 Cr unsecured loan addition u/s 68 after verifying director source. Remands Rs.1.01Cr cash payment (40A(3)) and restricts TDS default (40(a)(ia)) additions.
ITAT Chennai rules sale of land 16 km from municipality is exempt agricultural income (Anita Vs ITO). Deletes LTCG and restricts Sec 14A disallowance to exempt income.
