ITAT Raipur set aside a Rs. 14.73 lakh addition under Section 69C after finding the CIT(A) misinterpreted the assessee’s wife’s financial capacity, affirming proper documentation supports legitimate expenditure.
The Tribunal held that an addition based solely on a third-party excel sheet, without any direct evidence of cash payment, was unsustainable. With a complete RTGS trail, registered deed, and vendor confirmation proving bank-only payment, the ITAT ordered deletion of the Section 69 addition.
Tribunal held that an unsigned 143(2) notice violates Section 282A(1), making reassessment void. Ruling confirms that signature is mandatory and cannot be cured under Section 292B.
Tribunal deleted Rs. 10 lakh addition made under Section 68 where lender’s deposits were not independently verified. The assessee had no failure in proving identity, genuineness, or creditworthiness. Key takeaway: mere timing of lender’s bank deposits cannot trigger Section 68 addition without corroborative evidence
The Tribunal held that the CIT(A) failed to pass a reasoned speaking order and dismissed the appeal ex-parte without proving deliberate non-compliance. The matter was remanded with one final opportunity, reinforcing natural justice requirements.
ITAT held that cash deposits made by directors before investing in share capital cannot be treated as unexplained income of the company. The ruling emphasizes that proper identity, creditworthiness, and genuineness documentation must be evaluated before invoking Section 68.
The Tribunal ruled that additions based on third-party search without giving the assessee a chance to examine evidence violated natural justice, deleting ₹2.04 Cr and ₹64.11 Lakh for AY 2018-19 & 2019-20.
ITAT Raipur allowed the appeal, holding that addition of Rs.11.84 lakh under Section 68 was unsustainable as no direct evidence linked the assessee to alleged share manipulation.
Raipur ITAT remanded the section 68 addition of ₹14.3 lakh, observing that NFAC/CIT(A) failed to examine confirmations, ITRs, or facts. The order lacked independent reasoning and was set aside for fresh adjudication.
The ITAT Raipur restored the appeal regarding deletion of ₹15.81 crore addition, highlighting procedural lapses by CIT(A) in accepting new evidence without remand. Key takeaway: AO’s verification is crucial before deleting large additions.
