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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.
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 ruling clarifies that the benefit of extended timelines under TOLA was unavailable for A.Y. 2015–16. As a result, reassessment initiated after the cut-off date was held unsustainable.
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 additions treating shooting location receipts as house property income were premature. Authorities were directed to re-examine the claim after considering all relevant documents.
The Tribunal noted that share application money in the first year requires proper enquiry before invoking Section 68. Additions were deleted as statutory conditions were satisfied.
