Whether large cash deposits during demonetisation could be explained as cash sales. Ruling & Takeaway: The Tribunal upheld addition under section 69A, finding implausible sales patterns, rejected books, and lack of evidence; human probability prevailed over book entries.
The Tribunal found a prima facie mismatch between stock and cash sales during demonetisation. The issue was remanded for fresh verification by the Assessing Officer.
It was ruled that denial of registration merely because activities are at an initial stage is unjustified. The takeaway is that limited funds and phased implementation do not negate charitable intent.
It was ruled that refusal to condone delay, when justified, defeats substantive justice. The takeaway is that procedural delay should not block adjudication of intimation adjustments.
It was ruled that speculative losses from non-genuine share transactions cannot be adjusted against interest income. The decision reinforces strict application of sections 43(5) and 73 where delivery is doubtful.
The issue was confirmation of penalty without reasons. The Tribunal held that a non-speaking appellate order violates law and remanded the matter for fresh adjudication.
The Revenue disallowed 80P deduction by treating FDR interest as income from surplus funds. ITAT ruled Totgars applies only to surplus funds, not to statutory reserves mandated by co-operative law.
he Tribunal observed that confirmation of additions without examining affidavits and tax returns of close relatives is legally flawed. The matter was remanded for fresh adjudication.
ITAT ruled that deductions under section 80P cannot be disallowed at the CPC stage for returns filed after the due date prior to Finance Act 2021. The matter was remanded for proper verification by the AO.
The ruling clarifies that Section 153(3)(ii) operates as an exception to the normal limitation framework. When assessments are made to give effect to appellate directions involving special audits, no fixed time limit applies.
