The Kolkata ITAT held that penalty under Section 271(1)(c) cannot be levied where income addition is based on peak credit estimation. The Tribunal ruled that estimated additions do not automatically prove concealment or inaccurate particulars.
Supreme Court dismissed the challenge against reopening of assessment where the Gujarat High Court had upheld reassessment proceedings based on Investigation Wing material alleging accommodation entries. The case reaffirmed that prima facie material is sufficient at the reopening stage.
Gujarat HC held that reassessment under Sections 147 and 148 was valid where Assessing Officer received fresh investigation material alleging accommodation entries. Court observed that prima facie tangible material is sufficient at reopening stage.
Bombay High Court upheld deletion of disallowance under Section 40(a)(ia) where there was only short deduction of TDS and the recipients had already paid taxes. The Court also reiterated that the second proviso to Section 40(a)(ia) operates retrospectively from 01.04.2005.
The ITAT upheld disallowance of ₹11.71 lakh towards loan processing fees after finding that the loans were obtained for broader business purposes and not for acquiring the property generating rental income. The ruling clarified the limited scope of deductions available under Section 24(b).
ITAT Mumbai held that stamp duty valuation on the date of allotment should be considered where property consideration was fixed earlier and payments were made through banking channels before registration.
The Karnataka High Court held that blocking of Electronic Credit Ledger under Rule 86A without granting a prior hearing violated principles of natural justice and caused serious civil consequences.
ITAT Raipur held that reassessment proceedings were invalid where documents and information forming the basis of reopening under Section 148 were withheld from the assessee.
The Tribunal ruled that recording satisfaction under Section 153C is not a mechanical exercise and must clearly establish the relevance of seized material to the assessee’s income.
The Kolkata ITAT held that a commercial loan repaid within the same financial year along with interest and TDS compliance could not be treated as a bogus accommodation entry under Section 68. The Tribunal ruled that documentary evidence and banking transactions established the genuineness of the loan.
