The Tribunal found that the assessee had furnished agricultural sale bills, revenue records, and bank details supporting the cash deposits. Considering the facts and circumstances, only a partial addition was sustained.
ITAT Rajkot held that reassessment proceedings were invalid because the approving authority merely stated Yes, I am satisfied without independent application of mind. The Tribunal treated Section 151 approval as a mandatory procedural safeguard.
The Tribunal held that lack of awareness of the assessment order and limited knowledge of tax law constituted sufficient cause for delay. The matter was restored for reconsideration on merits.
The Tribunal held that unsigned excel sheets without supporting evidence cannot justify additions. It ruled that absence of corroboration and cross-examination renders such documents unreliable.
The issue was whether income from hybrid seed production on leased land qualifies as agricultural income. The Tribunal held that ownership is not necessary if the assessee exercises control, bears risk, and performs agricultural operations.
The issue was validity of reopening based on approval lacking proper application of mind. The Tribunal held such mechanical approval invalid, rendering the reassessment void.
The Tribunal rejected the Revenue’s argument that taxpayers must seek AO determination under Section 195(2) in all cases. It held that such obligation arises only when income is chargeable to tax in India. This ruling reduces procedural burden where taxability itself is absent.
The Tribunal held that the reassessment notice was time-barred under the Supreme Court ruling on surviving period. Notices issued beyond the permissible limit were declared invalid.
The Tribunal ruled that adopting stamp duty value without obtaining a DVO report violates Section 50C when the assessee disputes fair market value. The matter was restored for fresh adjudication after obtaining proper valuation.
Penalty imposed under Section 271AAA was set aside, holding that only the Assessing Officer is empowered to levy such penalty. The Tribunal further ruled that once quantum addition is deleted, penalty cannot survive.
