The tribunal held that cash deposits cannot be treated as unexplained when sufficient recorded cash receipts exist. Once books support availability, Section 68 additions fail.
ITAT Mumbai deletes ₹27.40 lakh addition under Section 69A, holding cash deposits as genuine business advances for car bookings, duly supported by confirmations, PAN, and invoices; non-response of customers cannot justify addition without proper verification.
The ruling clarified that unverified electronic records and third-party statements cannot justify additions without proper verification. The absence of direct linkage and corroboration led to deletion of additions.
ITAT Mumbai rules scholarships to Indian students studying abroad qualify as valid charitable application in India. Denial of 12AB and 80G set aside, clarifying registration stage scope is limited to objects and genuineness.
ITAT Mumbai quashes ₹1.64 Cr reassessment for faceless violation & time-barred notice u/s 148; holds jurisdictional defect fatal, TOLA cannot extend limitation.
The ruling emphasizes that once the Transfer Pricing Officer accepts the arm’s length nature of a transaction, the Assessing Officer cannot question its reasonableness. The disallowance was deleted as the interest rate complied with transfer pricing norms and reflected commercial reality.
The case examined whether failure to consider a binding tribunal precedent constitutes an error. The ITAT held that such non-consideration is a mistake apparent on record and recalled the issue for fresh adjudication.
The Tribunal deleted the addition after finding that cash deposits were supported by disclosed sale consideration and documentary evidence. It held that unverified objections could not override confirmed transactions.
The issue was estimation of commission income from alleged accommodation entries. The tribunal held that addition should be restricted to 0.5% on proven transactions, not inflated amounts.
The issue was whether donation to a political party qualified for deduction under Section 80GGC. The tribunal held the claim was not genuine and upheld disallowance due to lack of credibility.
