The Tribunal deleted additions where the Revenue failed to prove actual cash transactions. It emphasized that suspicion and assumptions cannot replace evidence. The ruling protects taxpayers from arbitrary additions.
The Tribunal condoned delay due to reasonable cause and addressed valuation mismatch. It remanded the issue for DVO-based reassessment. The ruling balances procedural leniency with substantive justice.
ITAT Mumbai remanded ₹95.81 lakh commission disallowance, holding that non-response to Section 133(6) notices alone cannot justify addition without proper verification; ad-hoc expense disallowance reduced from 20% to 10%.
The issue was whether addition under Section 56(2)(x) based on stamp value was justified despite conflicting private valuation. The Tribunal directed the AO to obtain a DVO report and reconsider the addition as per law.
The Tribunal held that penalty under Section 272A(1)(d) cannot be imposed when notices were sent to an inaccessible hacked email. It accepted that delayed compliance had a reasonable cause. The ruling emphasizes fairness in penalty proceedings.
The Tribunal held that failure to specify a clear purpose in Form 10 invalidates accumulation claims under Section 11(2). However, it allowed reconsideration to verify actual utilization. The ruling highlights the need for precise disclosures.
ITAT Mumbai held that CIT(A) cannot enhance income by introducing a new issue not examined by the Assessing Officer. The ruling clarifies that such action exceeds jurisdiction under Section 251 and must be addressed through other provisions.
Transfer of passive infrastructure (PI) assets under a court-approved scheme of demerger without consideration qualified as a gift under Section 47(iii), thereby legitimizing the claim of depreciation on such assets.
The Tribunal held that loan repayment cannot be treated as unexplained cash credit under section 68. The addition was deleted as it was based on incorrect classification of repayment as fresh loan.
The Tribunal examined whether an increase in loans was due to fresh borrowing or reclassification. It remanded the matter for verification, holding that no addition is warranted if no new funds were received.
