The Tribunal found that the AO relied only on general information without corroborative material. The ruling emphasizes that suspicion cannot replace proof in tax proceedings.
The tribunal ruled that revisionary powers cannot be exercised without questioning the statutory approval under Section 153D. Absence of such examination renders Section 263 action invalid.
The notice issued after the permissible window calculated under TOLA and judicial rulings was held void. The case highlights strict adherence to limitation timelines.
The Tribunal ruled that supplying only a summary of reasons is insufficient in law. The failure to furnish recorded reasons vitiated the entire reassessment.
The Tribunal held that CIT(A) cannot sustain addition under Section 68 without issuing notice under Section 251(2). It also noted that the AO had already accepted evidences of investors.
ITAT Mumbai held delay and ex-parte orders cannot override justice. ₹64.8 lakh addition u/s 69 set aside; case remanded for fresh examination, giving assessee opportunity to submit evidence.
The CIT(A) upheld additions without discussing merits or legal issues. The Tribunal ruled that a speaking order is mandatory and remanded the matter for fresh adjudication.
The reassessment notice issued within four years was wrongly quashed by applying amended law. The Tribunal restored the matter, emphasizing correct application of applicable provisions.
The Tribunal held that once the assessee disputes stamp duty valuation, referral to a Valuation Officer is necessary. The matter was remanded for fresh determination.
The case examined whether promotional expenses should be capitalized under the project completion method. The Tribunal held that such expenses, not linked to inventory development, are allowable as revenue expenditure.
