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The Tribunal held that revision under Section 263 is invalid without proving both error and revenue prejudice. The AO’s order was restored as valid.
The tribunal held that reassessment fails if no addition is made on the issue cited for reopening. Additions on unrelated grounds were declared beyond jurisdiction.
The Tribunal held that tenancy supported by rent receipts, bills, and agreements cannot be treated as a sham. It upheld exemption under Section 54F on surrender of tenancy rights.
The Tribunal upheld deletion of addition as seized loose sheets lacked key details and no supporting evidence proved unaccounted sales. Reliance solely on such documents was held insufficient.
The Tribunal ruled that revision under Section 263 requires examination of approval granted under Section 153D. Without establishing any defect in such approval, the assessment cannot be termed erroneous. The decision limits arbitrary revision powers.
The Tribunal ruled that incorrect invocation of Section 69A does not invalidate the addition. Since the loan was found to be an accommodation entry, it was sustained under Section 68. The decision emphasizes substance over technical defects.
ITAT held that the assessee discharged the burden of proving identity, creditworthiness, and genuineness. Addition was deleted as AO relied only on suspicion without evidence.
ITAT upheld addition under Section 68 as the assessee failed to prove identity, creditworthiness, and genuineness of unsecured loans. It ruled that mere submissions without proper evidence do not discharge the initial onus, and addition was rightly sustained.
ITAT set aside the addition made under Section 68 due to incomplete verification of a large gift transaction. It remanded the case for fresh examination with proper evidence and opportunity.
The case addressed whether reassessment can proceed before disposing of objections. The Tribunal ruled that such action breaches mandatory legal procedure, leading to quashing of the assessment.
