The Tribunal quashed reassessment proceedings after finding that the Assessing Officer already possessed complete information before issuing notice under section 148.
The ITAT held that gross bank credits cannot be treated as unexplained income where evidence shows the assessee merely facilitated transactions for a third party. Only a reasonable commission was directed to be taxed.
Addressing alleged cash discrepancies and debtor recoveries, the Tribunal held that such amounts form part of presumptive business receipts. Without books or adverse evidence, additions were unjustified.
The issue was whether unsecured loans could be added again after being accepted in prior proceedings. The Tribunal ruled that absence of new material bars reassessment on identical facts.
The Tribunal held that PF contribution paid within the statutory due date cannot be disallowed due to a clerical mistake. Bank records proved timely payment, nullifying the addition.
Holding the assessment void ab initio due to limitation, the Tribunal quashed the revision orders. The ruling underscores that revision cannot cure a fundamentally invalid assessment.
The Tribunal held that reassessment initiated with approval from an incorrect authority violates section 151. Such jurisdictional defect renders the section 148 notice void.
The Tribunal held that bank cash deposits explained through audited books and recorded transactions cannot be added. In absence of rejection of accounts, the addition was unsustainable.
The Tribunal held that cash routed through a bank account for money transfer activity cannot be taxed in full when only commission is earned. Once commission income is offered to tax, no further addition is justified.
Validity of reopening and quantum of addition for alleged bogus purchases. Reopening upheld; addition restricted to 5% profit element. Key takeaway: Where sales and quantities are accepted, only embedded profits can be added.
