The issue was whether entire cash deposits and unsecured loans could be taxed as unexplained income. The Tribunal held that only the embedded profit is taxable and restricted the addition to 10%.
The Tribunal held that a co-operative bank must deduct TDS on interest beyond the threshold despite payment to co-operative societies. Specific TDS provisions were held to override general exemptions.
The issue was whether Section 50 can apply when no depreciation was ever claimed or allowed on cars. The Tribunal held that without actual depreciation, Section 50 cannot be invoked and the addition was deleted.
The Tribunal clarified that confirmation of a Section 14A read with Rule 8D disallowance does not automatically justify penalty. Independent findings showing inaccurate particulars or concealment are mandatory.
Where the extent of inflated purchases cannot be quantified and is restricted to a nominal percentage, penalty provisions do not apply. The ruling reinforces the distinction between estimated additions and proven concealment.
The issue was whether the entire purchase amount could be added under Section 69C based solely on an entry-operator’s denial. The Tribunal ruled that since sales were accepted and books not rejected, only a 10% estimated disallowance was justified.
It was held that applying Sections 69/69A read with Section 115BBE without examining penalty under Section 271AAC justified revision. The PCIT’s direction to reframe the assessment was sustained.
The issue was whether a transfer pricing adjustment could survive when based solely on DRI allegations later dropped. The Tribunal held that once customs authorities exonerated the assessee, the TP adjustment had no foundation and was rightly deleted.
The ITAT held that reassessment notices issued by the Jurisdictional AO after 29.03.2022 are void under the faceless regime. Since the assessments were invalid, all consequential penalty orders were also quashed.
The issue was whether the entire amount of alleged bogus purchases could be disallowed under Section 69C. ITAT Mumbai held that in the absence of corroborative evidence, only the profit element can be taxed, restricting the addition to 6%.
