The Tribunal upheld deletion of a ₹4.41 crore addition where the assessment relied only on a survey statement later retracted. It ruled that, without independent evidence, such admissions and loose papers cannot justify additions.
The issue was whether a loan can be treated as unexplained despite full repayment within the year. The Tribunal held that once receipt and repayment are proved through banking channels, section 68 cannot apply.
The issue was whether declared business income can be overlooked while estimating profits after rejecting books. The Tribunal held that ignoring returned income leads to double taxation and directed its set-off.
The issue was whether the company could be asked to explain the source of shareholders funds for a pre-2013 year. The Tribunal held that the proviso to section 68 is prospective, making the addition unsustainable.
The issue was whether the appellate authority could delete a large unexplained investment without following Rule 46A. The Tribunal held that bypassing mandatory procedure invalidates the relief, and the matter must be re-examined.
The issue was reopening beyond four years after a completed scrutiny assessment. The Tribunal held the reassessment invalid as there was no finding of failure to disclose material facts, a mandatory precondition under the proviso to section 147.
The issue was whether the appellate authority could enhance income by adding entire purchases when the AO had only made a small commission addition. The Tribunal held that such enhancement, without fresh material and beyond the subject matter of appeal, is illegal.
The Tribunal ruled that absence of formal registers or third-party bills does not automatically make expenses bogus. Additions based purely on estimates, without proof of inflation, are arbitrary and unsustainable.
The ITAT held that reassessment initiated in July 2022 for AY 2015-16 was barred by limitation. The ruling confirms that expired cases cannot be revived under the post-2021 reassessment framework.
ITAT found the recorded reasons vague and non-specific, failing to even identify the nature of alleged escapement. Such mechanical reasons render the notice under section 148 void ab initio.
