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Income Tax : Tribunal dismissed a Revenue appeal after finding that additions were made solely on basis of entries in a seized Excel file. It h...
The tribunal held that where the Assessing Officer conducted exhaustive enquiries and applied his mind in a 153C assessment, revision under section 263 is invalid. A mere change of opinion cannot justify reopening a concluded assessment.
The Tribunal examined whether repayment of earlier loans could be taxed as unexplained money. It held that once loans were accepted as genuine and repayment sources were explained, no addition could survive.
The issue was whether Section 153C proceedings could continue when seized material was handed over after 01.04.2021. The Tribunal ruled that such notices are barred by law, rendering the assessment void.
The Revenue treated seized cash entries as unexplained income under Section 69A. The Tribunal ruled that receipts from agricultural activities are exempt and cannot be taxed merely based on seized notings.
The reassessment relied entirely on allegations arising from a search on another entity. The Tribunal ruled that additions cannot survive without independent evidence directly linking the assessee.
The issue was whether third-party diaries and loose papers could establish receipt of unaccounted income. The Tribunal ruled that such papers, without authorship verification or corroboration, cannot fasten tax liability.
The issue was whether reassessment after three years was barred by limitation. The Tribunal held it valid since the escaped income exceeded ₹50 lakh, attracting the extended reopening window.
It was held that documented capital contributions supported by affidavits, bank records, and land evidence are explained credits. Assessing authorities cannot disregard undisputed financial capacity.
While reopening of assessment was sustained due to bank deposit information, the cash addition was deleted on merits. Proper explanation of source defeats Section 69A.
It was ruled that money received from a parent through banking channels constitutes an explained source. The addition under Section 69A was deleted as the transaction was fully traceable.
