The issue was whether revision could stand on incorrect factual assumptions. ITAT held that misreading records makes the revision invalid, reaffirming that Section 263 needs real errors.
The issue was whether a reassessment notice issued after the surviving limitation period was valid. The Tribunal held the notice time-barred in light of the Supreme Court ruling, rendering the entire reassessment invalid.
The AO accepted documents but still made an addition without pointing out defects. The Tribunal ruled that section 68 requires adverse findings, not assumptions.
The Tribunal upheld reassessment based on Investigation Wing material alleging accommodation entries. It ruled that such tangible inputs justified reopening despite a completed scrutiny assessment.
The Tribunal held that delayed filing of an audit report cannot justify wholesale disallowance of expenses at the CPC processing stage. Such action falls outside the limited scope of Section 143(1) adjustments.
The issue was whether an appeal could be dismissed solely for delay without examining merits. The Tribunal held that where delay is bona fide, technical rejection is improper and the matter must be decided on merits.
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.
