The Tribunal examined whether GST could be included in gross receipts for presumptive income. It held that GST is a statutory levy with no income element and must be excluded under section 44BB.
Tribunal confirmed that transfer of passive infrastructure assets is genuine and qualifies as a gift under section 47(iii), rejecting revenue’s claim of tax avoidance.
Lenders had confirmed loans in response to statutory notices, yet additions were made. The Tribunal upheld deletion by CIT(A), stressing the importance of uncontroverted confirmations. The ruling reinforces evidentiary discipline in Section 68 cases.
The Tribunal found that alleged cash payments lacked any agreement, bank trails, or confirmation from recipients, making the addition legally untenable. ITAT emphasized adherence to evidentiary standards under Section 65B and deleted the addition entirely.
The tribunal found that the income addition of ₹80 lakh was incorrectly attributed to the assessee personally instead of the company, allowing the appeal to proceed on merits.
ITAT held that Rule 8D cannot be applied automatically under section 14A; the AO must record satisfaction on the correctness of the assessee’s suomoto disallowance, quashing the incremental disallowance.
The ITAT held that jewellery tag prices in internal software cannot be equated with realised sales, deleting GP additions made without evidence of suppression.
Tribunal held that income cannot be added merely because it appears in Form 26AS and remanded matter to verify whether assessee actually received amounts corresponding to TDS credits.
The ITAT ruled that an addition under section 68 cannot be sustained solely on a retracted statement of a third party, deleting ₹81 lakh share capital added to income.
The tribunal held that absence of internet connectivity in a remote area was a valid reason for non-compliance and restored the registration application.
