Income Tax : ITAT held that where sales are not disputed, entire purchases cannot be disallowed. Only 15% profit element was taxed, reinforcing...
Income Tax : The Tribunal quashed reassessment proceedings as they were based on a mere change of opinion without any fresh tangible material. ...
Income Tax : The issue involved levy of late fees on TDS returns processed before statutory amendment. The Tribunal held that absence of enabli...
Income Tax : The Tribunal held that valuation without giving the assessee an opportunity to object violates natural justice. It remanded the ma...
Income Tax : The Tribunal condoned delay due to reasonable cause and addressed valuation mismatch. It remanded the issue for DVO-based reassess...
Despite deficiencies in documentation, agricultural activity and landholding were undisputed. The Tribunal granted partial relief while sustaining a modest addition. The decision highlights a balanced approach where activity is proven but evidence is imperfect.
The Tribunal held that reassessment beyond three years is invalid where the alleged escaped income is below ₹50 lakh. A notice issued for a ₹5 lakh donation was declared void ab initio.
Taxing a debenture waiver as revenue income was challenged. The Tribunal rejected the approach, holding the waiver arose from capital financing and not trading operations. The ruling confirms that capital restructuring gains are not taxable by default.
The Tribunal held that reassessment notices issued after 01.04.2021 for AY 2015-16 are time-barred. Such reopening is invalid despite reliance on TOLA, and must be quashed.
Holding that actions prescribed by statute must be performed only in the specified manner, the Tribunal deleted the penalty. The case reinforces the importance of lawful service of notices before penal action.
The Tribunal found that estimating agricultural income solely on standard yield figures ignores real-world farming variables. The assessment was partly modified by limiting the addition to ₹50,000.
The Tribunal clarified that the law does not permit selective or partial rejection of books under Section 145(3). In absence of specific defects, additions based on probabilities alone were set aside.
The issue was whether income of a predecessor company for years before amalgamation can be reassessed in the hands of the successor. ITAT held that such clubbing is impermissible and the reassessment itself is void.
The Tribunal held that a bona fide mistake in claiming deduction under an incorrect section should not bar relief. The matter was remanded to verify eligibility under section 35(1)(ii).
Where capital subsidy was not received in the relevant year and no addition followed, reopening lacked basis. Mechanical reliance on audit objections was held unlawful.
