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Holding that the Assessing Officer recorded a mechanical satisfaction note without concrete incriminating evidence, the Tribunal dismissed the Revenues appeals and confirmed invalid jurisdiction under Section 153C.
ITAT held that a portion of cash paid could reasonably be sourced from accumulated withdrawals from joint bank accounts. The remaining unexplained amount was reduced on an estimated basis.
ITAT Mumbai held that transfer pricing addition made in respect of Letter of Comfort rightly deleted since Letter of Comfort didn’t constitute an International Transaction. Accordingly, order passed by CIT(A) upheld to that extent.
The Tribunal held that acceptance of returned income without examining material indicating possible unaccounted cash investment amounts to lack of inquiry. Section 263 revision was therefore lawfully sustained.
ITAT Mumbai held that disallowance made under section 14A of the Income Tax Act added to Book Profits for computing taxes under section 115JB Income Tax Act deserved to be deleted.
ITAT ruled that once cash sales are recorded in audited books and accepted by the AO, taxing the same deposits again would result in double addition. The deletion of ₹1.54 crore was upheld.
The Tribunal held that reassessment beyond four years is invalid where the assessee had fully disclosed material facts during original scrutiny. In absence of failure to disclose, reopening under Section 147 was quashed.
The ITAT held that approval under Section 151 was invalid as the PCIT merely noted As per Annexure without independent satisfaction. The reassessment under Section 147 was declared void ab initio.
Bombay High Court held that notice u/s. 148 of the Income Tax Act issued after obtaining sanction under section 151 from the non-competent authority is invalid and not sustainable in law. Accordingly, notice is liable to be quashed and petition is allowed.
The Tribunal found no infirmity in the CIT(A)s detailed order deleting additions based on proper verification of evidence. All grounds raised by Revenue were rejected, and cross-objection became infructuous.
