ITAT Jaipur held that additions for unexplained sales and investment could not survive once the CESTAT rejected allegations of clandestine removal of goods. The Tribunal deleted additions made under Sections 69A and 69C.
The Tribunal held that reopening under Section 147 was invalid where it was based on third-party search material. It ruled that Section 153C was the correct legal route, leading to deletion of additions.
The Tribunal ruled that withdrawing a deduction in response to a Section 148 notice does not erase underreporting. Penalty for misrepresentation under Section 270A was upheld.
The tribunal allowed a remand where unexplained cash deposits were added based on a PAN-linked account. The key takeaway is that effective opportunity must be given to disown alleged accounts.
The issue was whether rental income from land qualified as agricultural income without supporting evidence. The Tribunal held that inadequate proof justified remanding the matter to the Assessing Officer for fresh verification.
Capital gains arose from land compulsorily acquired by a government authority. ITAT directed the AO to re-examine eligibility for exemption under Section 10(37).
The reassessment was initiated for AY 2013-14 using reasons recorded for AY 2012-13. ITAT held that reopening for the wrong year is void, causing the entire Section 147 assessment to collapse.
ITAT Jaipur confirmed that Section 270A(6)(b) exclusion is inapplicable when accounts are incorrect or incomplete. Key takeaway: defective records make estimated disallowances liable to penalty.
The issue was whether leave encashment exemption should be capped at ₹3 lakh or ₹25 lakh. ITAT held that the enhanced ₹25 lakh limit applies, making the entire ₹13.12 lakh fully exempt.
The Tribunal dismissed the appeals as time-barred since no application for condonation of delay was filed despite repeated opportunities. In the absence of any explanation, the appeals were held not maintainable.
