The Tribunal noted that loans were part of regular business transactions with repayments in the same year. It held that such conduct strengthens the claim of genuineness. The case highlights the relevance of transaction pattern in tax scrutiny.
The issue was whether entire purchases can be disallowed as bogus under Section 69C. The tribunal held that when sales are accepted, only the profit element (15%) can be taxed, not the full purchase value.
Consistency over technicalities: ITAT Mumbai allowed actuarial pension provision as an ascertained liability, rejected mechanical disallowances, and held CBDT instructions cannot override the Income-tax Act.
ITAT held that reassessment beyond three years requires approval from the higher authority, not PCIT. Since approval was wrongly obtained, the entire reassessment was quashed.
The Tribunal found that once additions under Sections 68 and 69C were deleted, penalty became infructuous. The ruling highlights the dependency of penalty on assessment findings.
ITAT held that absence of an irrevocability clause cannot justify rejection of 80G approval. The case was remanded to CIT(E) to reconsider in line with binding High Court ruling.
ITAT allowed additional evidence filed by the legal heir and remanded the matter to the AO for verification. The key takeaway is that justice requires giving opportunity where evidence was earlier unavailable.
The Tribunal noted that the assessee provided affidavits, bank statements, and financials of contributors. The addition was deleted as the source stood satisfactorily explained.
The tribunal ruled that failure to strike off irrelevant portions in penalty notice makes it legally defective. Such ambiguity invalidates the entire penalty levy.
The Tribunal held that audited accounts cannot replace documentary evidence for claiming application of income. The case was remanded for fresh verification.
