The Tribunal held that compensatory interest under Section 234B could not be charged when seized cash exceeding the tax liability was already in Revenue’s possession. It directed complete deletion of the interest.
Tribunal held that purchase of land outside the prescribed period does not automatically disqualify exemption on construction of a residential house. Construction expenditure incurred within the time limit prescribed under Section 54 may still qualify for deduction. The issue was remanded for verification of actual construction costs.
The Tribunal set aside the CIT(A)’s order because the appeal was dismissed on limitation without properly examining delay condonation grounds. It held that non-speaking orders passed without adequate hearing violate principles of natural justice and require fresh adjudication.
The Tribunal held that a surrender during survey cannot justify additions without supporting material. Statements under Section 133A lack evidentiary value unless backed by records. Additions based solely on surrender were deleted.
The assessee argued that revision proceedings were vitiated as they followed an audit objection. The ITAT rejected this plea, holding that audit-based information can validly trigger revision if conditions of section 263 are met.
ITAT Jabalpur held that CIT(A) cannot blindly follow PCIT directions under section 263. Appellate authorities must independently consider evidence and objections before confirming additions.
The Tribunal ruled that unexplained investment cannot be added without confronting the assessee with the Koinex transaction data relied upon by the AO. Matter remanded for fresh verification.
Tribunal held that an investment already assessed substantively in another person’s hands cannot again be taxed under Section 69. The case was remanded to avoid double taxation and ensure consistent adjudication.
ITAT Jabalpur held that additions for unexplained investment in agricultural land cannot be made without proper inquiry into the co-owner’s source of funds. The case has been restored for de novo consideration.
ITAT Jabalpur dismissed the Revenue’s appeal regarding the eligibility of Section 80P deduction for a co-operative society’s Business Correspondent income, citing the CBDT’s revised monetary limit for appeals.
