The ITAT ruled that extensive repairs to a 25-year-old factory building were revenue in nature since no new asset or enduring advantage arose. The addition treating the expense as capital was deleted.
The case addressed whether exemption could be disallowed through prima facie adjustment under section 143(1). The Tribunal held such denial impermissible and ordered fresh consideration.
The Tribunal examined whether cost of acquisition could be fixed on assumptions. It held that government-notified MVR rates must be considered and ad-hoc estimates cannot replace statutory valuation methods.
ITAT Patna held that consolidated approval under section 153D of the Income Tax Act granted in mechanical manner by JCIT without application of mind is invalid and hence assessment framed thereon is liable to be quashed.
The Tribunal held that while fee suppression was established during survey proceedings, the entire difference could not be taxed. Only the gross profit on suppressed receipts, excluding GST, is chargeable to tax.
ITAT ruled that the AO’s omission to apply TDS provisions on freight charges warrants revision. Proper application of statutory disallowances is mandatory in reassessment proceedings.
It was ruled that money received from a parent through banking channels constitutes an explained source. The addition under Section 69A was deleted as the transaction was fully traceable.
The Tribunal held that NFAC had no authority to pass reassessment orders before the faceless reassessment notification became operative. As a result, the entire assessment was quashed. The ruling highlights that participation by the assessee cannot cure jurisdictional defects.
The addition was sustained on the ground that earlier cash deposits were not explained. The Tribunal held that the explanation of medical exigency and redeposit was reasonable and directed deletion.
The tribunal rejected demand raised solely due to Form 26AS mismatch caused by employer non-deposit of TDS. The key principle is that employees cannot be penalised for failures beyond their control.
