The Tribunal held that reopening beyond three years is impermissible where alleged escaped income is below ₹50 lakh. Since the notice violated Section 151, the reassessment was quashed.
The Tribunal held that alleged on-money addition based solely on third-party loose papers is unsustainable. In absence of independent evidence linking the assessee to unaccounted payment, the addition was deleted.
Rejecting reliance on time lapse and regulatory issues, the Tribunal held that a trading liability remains valid unless actually extinguished. The addition under Section 41(1) was therefore deleted.
The Tribunal deleted ₹20,00,055 added as unexplained income after finding the transaction was based on mistaken identity. No evidence proved that the assessee received funds from the alleged shell company.
The Tribunal clarified that passing an order in the name of a non-existent entity is not a mere procedural defect. It held that participation in proceedings does not validate a void assessment.
ITAT ruled that without rejecting books of account or disproving sales, addition of aggregate cash deposits is unsustainable. Detailed reconciliations established nexus with business receipts.
Recognizing the 10% tolerance band as a beneficial amendment, the Tribunal applied it retrospectively. The ruling clarifies that minor valuation gaps cannot lead to artificial income additions.
ITAT ruled that reassessment made pursuant to a quashed Section 263 order has no legal basis. Subsequent additions cannot stand once the revision itself is annulled.
The Tribunal ruled that TDS credit can be granted even if not fully reflected in Form 26AS, subject to verification. The deductee should not be penalized for the deductor’s failure to deposit tax.
With the Section 50C addition and 54F disallowance deleted, the Tribunal held that the penalty under Section 271(1)(c) could not survive. It emphasized that penalty cannot stand when the underlying additions are removed.
