ITAT Kolkata condoned an extraordinary delay in filing appeals, emphasizing that genuine and unavoidable reasons justify late filing, allowing the appeals to proceed for adjudication.
The Tribunal held that conflicting judicial views on Section 10(38) exemption made the issue debatable. Since the assessee disclosed all facts, penalty for concealment could not survive despite later denial of exemption.
Tribunal remanded the case after finding that documentary evidence submitted during assessment was not examined. The matter is sent back for fresh evaluation with an opportunity of hearing.
ITAT Kolkata ruled that WhatsApp chats without corroboration cannot be treated as unexplained income under Section 69A. All additions based solely on chats were deleted, emphasizing the need for tangible evidence.
ITAT ruled that reopening assessment under Section 147 is invalid if the filed return is ignored. The case was remitted for fresh consideration after allowing the assessee to substantiate claims under Section 54F.
The ITAT held that a provisional addition under Section 56(2)(x) cannot be finalized without a Departmental Valuation Officer’s report. The case was remitted to the AO for proper valuation and reassessment.
Tribunal held that identity, creditworthiness, and genuineness of shareholders were proven through documents filed before AO and CIT(A). Since authorities ignored valid evidence, the section 68 addition was deleted.
The Tribunal held that unexplained money addition cannot stand when the AO ignores direct verification from the bank. Matter restored to the AO to summon the bank and tax only actual interest income.
ITAT Kolkata ruled that cash advances discovered during a survey must be assessed as business income, not unexplained cash credit under Section 68, making the exercise tax-neutral.
The ITAT held that the alleged bogus purchases could not stand when the assessee produced complete documentary evidence showing genuine procurement and consumption. With no contrary evidence from the AO, the 69C addition was removed.
