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Income Tax : The issue was whether reassessment could be initiated after four years without fresh evidence. The court held such reopening inval...
Income Tax : The issue was whether reassessment notice issued without approval from the correct authority is valid. The tribunal held it invali...
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Once the reassessment was quashed for jurisdictional and limitation defects, the Revenues appeal on merits became infructuous. The decision underscores the primacy of legal compliance in reassessment cases.
The Revenue alleged unexplained cash credits despite documentary evidence. The Tribunal ruled that once loans are repaid with interest and TDS, Section 68 cannot be invoked in isolation.
Cash deposits were added as unexplained money due to alleged lack of proof. The Tribunal ruled that a plausible and documented source cannot be rejected without contrary evidence.
The Tribunal upheld taxation of rental receipts as income from house property because the companys principal object was not property letting. It ruled that business income treatment cannot be claimed merely based on incidental objects in the memorandum.
The case examined whether other additions can be made when the reopening issue is not sustained. The Tribunal held that reassessment cannot be used as a roving enquiry.
The reassessment was struck down because it relied exclusively on third-party search material. The ruling clarifies that section 153C, not section 147, must be invoked where incriminating evidence emerges from another persons search.
The issue was whether reassessment could be initiated for an amount implicitly accepted in original assessment. The Tribunal ruled that reopening amounted to change of opinion and was legally unsustainable.
The issue involved purchases routed through entry providers to regularise grey-market transactions. The Tribunal held that taxing the whole purchase amount is incorrect; only excess profit may be assessed.
The issue involved taxing a marginal valuation difference on property purchase. The Tribunal deleted the addition as the variation was below the statutory tolerance threshold. The decision confirms that minor deviations alone cannot be treated as taxable income.
The Tribunal held that unsecured loans cannot be treated as unexplained once lenders confirm transactions and respond to section 133(6) notices. Suspicion without evidence cannot justify section 68 additions.
