The Tribunal held that additions cannot be sustained without incriminating material directly connecting the assessee to alleged cash payments. Reliance solely on third-party data was found insufficient. The ruling reinforces the need for concrete evidence in tax additions.
The Tribunal upheld reduced addition as earlier years’ rulings fixed profit element at 0.2%. It stressed that consistent facts require consistent treatment. Key takeaway: uniform approach must be followed across years.
ITAT Pune deletes ₹4.83 lakh penalty under Section 271(1)(c), holding that a bona fide difference in share valuation methods (NAV vs DCF) does not amount to furnishing inaccurate particulars; mere rejection of a claim cannot trigger penalty.
The Tribunal held that additions under Section 153C cannot be sustained when based on unverified third-party statements and documents. It found the evidence lacked credibility and was not corroborated. The ruling highlights strict evidentiary standards in search-based assessments.
The Tribunal held that reopening of assessment is invalid when reasons lack details like transaction nature, parties, and dates. It emphasized that vague information and absence of independent application of mind cannot justify reassessment. The ruling reinforces strict standards for valid reopening under tax law.
The Tribunal restored the case as the CIT(A) admitted additional evidence without giving the AO an opportunity to verify it. It held that violation of Rule 46A renders the order procedurally defective.
The case involved disallowance of deduction under Section 80P due to delayed return filing. The Tribunal ruled that the issue must be reconsidered after the authority decides the condonation request.
ITAT observed that the assessee provided invoices, bank records, and tax documents supporting purchases. Since sales were undisputed, full disallowance was unwarranted. The ruling highlights balanced approach in such cases.
ITAT Hyderabad holds that Section 249(4)(b) cannot bar appeal where no income is admitted and no advance tax is payable; sets aside dismissal and directs AO to treat demonetisation cash deposits as business turnover (if normal) and estimate income u/s 44AD instead of Section 69A addition.
The court held that a provisional attachment under Section 83 ceases once a final order under Section 74 is issued. The ruling reinforces that subsequent challenges must focus on the final order, not interim measures.
