Lucknow ITAT held that disallowance under Section 14A read with Rule 8D cannot exceed the exempt dividend income earned by the assessee. The Tribunal restricted the addition to the actual exempt income amount.
The decision underscores that failure to follow the prescribed valuation procedure under section 50C leads to invalidation of additions. The Tribunal ruled in favor of the assessee due to lack of proper DVO reference.
The Tribunal ruled that bank deposits cannot be treated as unexplained income when linked to regular business activity. It upheld that consistent past records supported the assessee’s claim of business receipts.
The issue was whether protective addition can survive when income is already taxed elsewhere. ITAT held that once income attains finality in another assessee’s case, protective addition cannot be sustained.
The Tribunal found that the assessee was not given adequate opportunity to present its case. It set aside the order and directed fresh assessment after proper hearing.
The Tribunal held the assessment invalid as no mandatory notice under Section 143(2) was issued. The key takeaway is that absence of such notice renders the entire assessment void.
The issue was whether multiple medical bills constituted a single transaction under Section 269ST. The Tribunal held that separately billed services are independent transactions, so penalty was not justified.
Retrospective cancellation of registration was held to be invalid as the scheme of Act did not permit cancellation of registration under Section 12AA(3) with retrospective effect in absence of explicit statutory authority.
The Tribunal held that purchases cannot be treated as bogus merely because the supplier did not file an income tax return. Verified GST filings and inventory records established transaction genuineness.
The Tribunal set aside adjustments made under Section 143(1) after finding ambiguity on whether reasonable opportunity was granted. Issues were remitted to the Assessing Officer for fresh examination.
