The Court ruled that provisional attachment under Section 83(1) cannot continue beyond one year as per Section 83(2). The attachment order was held to have lapsed by operation of law.
The Tribunal held that reopening beyond three years is impermissible where alleged escaped income is below ₹50 lakh. Since the notice violated Section 151, the reassessment was quashed.
The Tribunal ruled that since the assessment was legally correct when passed, invoking Section 154 after a later Supreme Court decision was impermissible. The addition was consequently deleted.
The Tribunal deleted ₹35.22 lakh added under Section 68 for cash deposits during demonetisation. It held that audited books, recorded cash sales, and sufficient cash balance fully explained the deposits.
The Tribunal held that alleged on-money addition based solely on third-party loose papers is unsustainable. In absence of independent evidence linking the assessee to unaccounted payment, the addition was deleted.
The Tribunal ruled that invoking Section 68 on member deposits of a cooperative society was unjustified. Proper books, cash records, and member-wise details were ignored by the AO.
The Tribunal upheld deletion of ₹3.67 crore added as unexplained cash credit from Singapore art exhibition sales. It held that detailed export, remittance, and bank evidence fully established the genuineness and source of funds.
Rejecting reliance on time lapse and regulatory issues, the Tribunal held that a trading liability remains valid unless actually extinguished. The addition under Section 41(1) was therefore deleted.
The Tribunal deleted ₹20,00,055 added as unexplained income after finding the transaction was based on mistaken identity. No evidence proved that the assessee received funds from the alleged shell company.
ITAT held that once the concessional tax option under Section 115BAB is exercised in the first eligible year, it automatically applies to subsequent years. Technical defects in later returns cannot defeat the claim.
