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The appeal was dismissed as the assessee had already offered the disputed income to tax at 30%. The ruling clarifies that reassessment cannot survive when there is no loss of revenue or escaped income.
The Tribunal deleted a cash credit addition after finding that temporary family deposits were fully explained. The ruling confirms that genuine, short-term deposits cannot be taxed without contrary evidence.
The Tribunal set aside the appellate order after finding that the appeal was not adjudicated on merits. The matter was remanded to ensure proper consideration after granting adequate opportunity of hearing.
The decision limits tax exposure by holding that unexplained cash deposits during demonetization should be assessed on an estimated profit basis when business records are accepted.
Relying on precedents including rulings of the Delhi High Court, the Tribunal held that extrapolation across years is impermissible. The addition was struck down as being based on assumption rather than evidence.
The Tribunal held that once business receipts are taxed on an estimated basis, separate additions for payments and assets from the same receipts are impermissible. Only a net-profit estimation was sustained, deleting multiple cascading additions.
The Tribunal held that disallowance of interest for non-deduction of TDS cannot be automatic when paid to an NBFC. The Assessing Officer must first verify whether the payee has offered the income to tax.
Levy of interest under sections 234B and 234C on income arising from an APA. Interest was deleted as APA income crystallises only on signing, making advance-tax estimation impossible.
The case addressed whether exemption could be disallowed through prima facie adjustment under section 143(1). The Tribunal held such denial impermissible and ordered fresh consideration.
Delhi High Court held that employee’s contribution deposited after statutory due date under relevant Acts is disallowed under section 143(1)(a) of the Income Tax Act even if the same is paid before filing of income tax return. Accordingly, question is decided against appellant.