The case addressed whether additions can be made under Section 153A without incriminating material. The Court held that such additions are impermissible in completed assessments, reinforcing settled legal principles.
The court examined whether a final assessment order could stand without issuing a draft order to an eligible assessee. It held that bypassing the mandatory draft assessment process invalidates the final order and renders it void.
The court examined whether reopening an assessment based on previously scrutinized facts was valid. It held that reassessment without fresh tangible material amounts to a change of opinion and is without jurisdiction.
ITAT Hyderabad holds 12.5% profit estimation on ₹2.52 crore bank credits excessive; rejects commission agent claim due to lack of evidence but restricts income estimation to 4%, granting partial relief to the assessee.
The Tribunal held that interest earned from co-operative banks qualifies for deduction under Section 80P(2)(d). It clarified that co-operative banks are to be treated as co-operative societies. The ruling resolves disputes on eligibility of such income.
ITAT ruled that selling and distribution expenses cannot form part of work-in-progress. Such costs do not contribute to inventory creation and must be treated as revenue expenditure. The decision reinforces accounting standards in tax treatment.
The Court held that compensation paid to buyers for surrendering rights was incurred for business purposes and not capital in nature. It emphasized commercial expediency as a key factor. The ruling clarifies treatment of such payments in real estate business.
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.
