The Tribunal upheld tax addition where agricultural land was acquired below stamp duty valuation and DVO-determined fair market value. It ruled that agricultural status of land does not exclude applicability of section 56(2)(x).
The ITAT Surat held that abnormal price rise in a penny stock and surrounding circumstances justified treating claimed LTCG as unexplained income under Section 68. The Tribunal found the transactions to be part of a pre-arranged accommodation entry scheme.
The ITAT Surat held that bank transactions reflected cheque discounting business activity and could not be fully treated as unexplained cash credits under Section 68. Only estimated commission income and profit were sustained.
ITAT ruled that deduction under Section 80JJAA could not be claimed where the business was acquired through amalgamation. The Tribunal held that transfer of assets, liabilities, and business operations constituted business reorganisation under the Act.
The ITAT Surat remanded a case involving a Rs.30 lakh gift treated as unexplained cash credit under Section 68. The Tribunal allowed the assessee another opportunity to submit bank records and explain the source of the gift.
The ITAT Surat held that revision under Section 263 was invalid because the Assessing Officer had already conducted inquiries and examined relevant records. Mere discrepancies in Insight Portal GST data were held insufficient to render the assessment order erroneous.
ITAT Surat restored reassessment appeals to the CIT(A) after observing that the assessee should receive one final opportunity to present evidence. The Tribunal imposed costs due to partial compliance before the appellate authority.
The Tribunal held that revisionary powers cannot be used to substitute the AO’s view with that of the Pr. CIT. It emphasized that such substitution is beyond Section 263. The decision protects independent assessment decisions.
The assessee produced new evidence including invoices and tax returns of suppliers. The Tribunal held that these documents must be examined before deciding the issue.
The Tribunal held that a penalty notice lacking clarity on whether it relates to concealment or inaccurate particulars is invalid. It ruled that such a defect makes the penalty unsustainable.
