The court held that the 2-year time limit under Section 54 is mandatory and binding on authorities. However, delay can be condoned by High Courts under Article 226 in genuine cases to grant rightful refunds.
The case involved estimated addition on agricultural income and dismissal of appeal for non-prosecution. ITAT held such dismissal invalid and ruled that arbitrary estimation without evidence cannot sustain.
The Tribunal held that a notice issued under section 148 beyond the six-year limitation under the old law is invalid. It clarified that the first proviso to section 149 bars such reopening even under the amended regime.
The dispute concerned alleged bogus agricultural income taxed as unexplained money under Section 69A. The Tribunal set aside the addition and directed the AO to re-examine evidence before reaching a conclusion.
The issue was whether demonetisation cash deposits can be taxed as unexplained credits solely due to use of SBN. The ITAT held that proper explanation and records negate automatic addition under section 68.
The case examined if failure to conduct audit permits arbitrary profit estimation. The ITAT ruled that absence of audit alone cannot justify 8% estimation when books are maintained and not rejected.
The case involved addition for alleged on-money payment based on search findings of a builder. The ITAT ruled that absence of corroborative evidence and denial of cross-examination makes the addition unsustainable.
ITAT Mumbai held that deduction claimed by the assessee under section 80G of the Income Tax Act cannot be denied merely on the ground that the payment also formed part of CSR expenditure under the Companies Act.
ITAT Chennai held once the AO has conducted inquiry, examined replies and adopted a legally sustainable view, the same cannot be treated as erroneous. Accordingly, invocation of revisionary jurisdiction under section 263 of the Income Tax Act is not sustainable in law.
The Court held that failure to address objections regarding sample mismatch vitiates the order. It directed fresh adjudication with proper reasoning.
