The dispute concerned denial of TDS credit solely due to non-reflection in Form 26AS. The Tribunal held that Form 26AS is not conclusive and factual deduction of tax overrides system mismatch.
Despite Form 10E being duly filed online, the claim under section 89(1) was rejected on technical grounds. The Tribunal held that such rigidity defeats justice and directed the AO to examine the claim afresh.
The dispute arose from survey-based additions relying mainly on a statement and impounded agreement. The Tribunal held that the matter needed fresh examination and remanded it to the AO with one final opportunity.
ITAT Pune admitted affidavits and satellite images showing land under cultivation, restoring the issue to AO for reassessment. Proper evidence can overturn non-agri classification for capital gains.
ITAT Pune struck down a ₹34.28 lakh penalty issued after the company had merged, citing substantive illegality. Penalty orders must be issued in the name of a legally existing entity.
The assessee failed to file returns for two years preceding the capital increase. The Tribunal held that unexplained capital accretion must be taxed under section 68.
The dispute concerned cancellation of IDS benefits due to non-payment. The Tribunal held that once IDS lapses, undisclosed income is taxable with mandatory penalty.
The Tribunal observed that the purpose of revision is to protect revenue interests. When no tax demand arises in consequential proceedings, the revision order no longer calls for adjudication.
ITAT Pune condoned an 897-904 day delay in appeals, holding the delay was unintentional and due to incorrect guidance. The case highlights that bona fide professional errors can justify condonation of delay.
Pune ITAT restored the matter to the CIT(A) after the assessee argued that adequate opportunity was not provided to explain the source of funds received. The Tribunal directed fresh adjudication with proper hearing and liberty to file supporting evidence.
