The ruling highlights that mere failure to file return, without concealment or tax evasion, does not automatically attract Section 270A penalty. Bona fide explanation and TDS compliance protected the taxpayer.
Recognizing the 10% tolerance band as a beneficial amendment, the Tribunal applied it retrospectively. The ruling clarifies that minor valuation gaps cannot lead to artificial income additions.
ITAT upheld deletion of additions where assessment was framed under the wrong provision. Since the year fell within the block period of a non-searched person, Section 153C was mandatory.
ITAT ruled that reassessment made pursuant to a quashed Section 263 order has no legal basis. Subsequent additions cannot stand once the revision itself is annulled.
The Tribunal ruled that TDS credit can be granted even if not fully reflected in Form 26AS, subject to verification. The deductee should not be penalized for the deductor’s failure to deposit tax.
With the Section 50C addition and 54F disallowance deleted, the Tribunal held that the penalty under Section 271(1)(c) could not survive. It emphasized that penalty cannot stand when the underlying additions are removed.
ITAT ruled that revisionary powers cannot be invoked on vague suspicion. Where identity, creditworthiness, and genuineness are documented and examined, Section 263 cannot be sustained.
The Tribunal ruled that reassessment completed after the taxpayer s death without issuing notice to legal heirs is void ab initio. Legal heirs are not obligated to inform the Revenue about the death.
The Tribunal ruled that once cash sales are recorded in books and included in declared turnover, separate addition of deposits would result in double taxation. The entire ₹4.74 crore addition was deleted.
The Tribunal clarified that Goetze (India) does not bar appellate authorities from entertaining new claims. Where all facts are on record, the claim must be examined on merits.
