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The ITAT ruled that failure to issue a mandatory Section 143(2) notice and disregarding an e-verified return rendered the reassessment void. The addition of ₹50.50 lakh was deleted.
The Tribunal held that reopening based on Section 50C was unsustainable because the provision applies only to sellers, not purchasers of property. With the very foundation of reassessment failing, the addition based on circle-rate difference was deleted. The ruling underscores that incorrect legal assumptions cannot justify reopening under Section 147.
ITAT ruled that reopening was bad in law as reasons cited property purchases, while additions related to cash credits—showing no live nexus. The case reaffirms that reassessment must be based on specific, relevant material.
The Tribunal held that reopening the assessment on the same grounds already examined in the original scrutiny amounted to an impermissible change of opinion. With no new material on record, the reassessment was found invalid. The ruling reinforces that the AO cannot revisit an earlier view in the guise of section 147 proceedings.
Tribunal held that additions made solely on ex-parte proceedings cannot stand when the taxpayer was unable to comply due to age-related limitations. The case was remanded for fresh assessment with a direction to provide proper opportunity.
ITAT held that reassessment notices under sections 147/148 were invalid as the reasons were vague and lacked tangible evidence. Reopening cannot be used merely to verify or scrutinize transactions without proper justification.
ITAT held that additions based on an unsigned, unverified Excel sheet from a third party lacked evidentiary value. The reassessment was quashed as the assessee provided independent evidence disproving alleged on-money payments.
The Tribunal allowed the assessee’s claim under Section 44AD, recognizing the small kirana shop’s sales and deposits as genuine business income. Bank deposits corresponded with daily sales, and withdrawals matched purchase requirements, showing a consistent business pattern.
Additions for alleged on-money payments were disallowed because the evidence relied on by authorities contained errors and lacked authenticity. The decision highlights the need for corroborated, primary evidence in tax proceedings.
Tribunal remanded the case to the AO to reassess ULIP maturity receipts treated as unexplained investment after the exemption claim was not evaluated earlier.
