ITAT held that AYs 2011-12 and 2012-13 were time-barred since the 10-year window must be computed from the date of recorded satisfaction. The ruling reaffirms that out-of-range years cannot be assessed under 153C.
ITAT held that cash deposited during demonetization was fully backed by prior withdrawals exceeding ₹47 lakh. The ruling confirms that demonstrated cash availability defeats Section 68 additions.
Tribunal held that AY 2010–11 was beyond the statutory 10-year window, making the 153A assessment invalid. Time-barred years cannot be revived under extended search assessments.
Tribunal held that ownership records alone cannot justify agricultural income; absence of Khasra and produce-sale evidence required remand. Cultivation must be proved with proper documentation.
ITAT remanded assessment where substantial 69A addition was made without giving the assessee a chance to present his case. Procedural fairness is critical, even in non-filing scenarios.
The Tribunal held that reimbursement of foreign exchange loss on external commercial borrowing cannot be taxed under section 28(iv) as it is capital in nature, avoiding double taxation.
The ITAT held that the AO could not deny TDR cost in both AY 2018–19 and AY 2020–21, directing allowance of the deduction. Authorities cannot blow hot and cold on the same issue across years.
Tribunal holds that selling goods below cost does not create marketing intangibles and cannot be capitalised as brand-building expenditure. ESOP reimbursements are reaffirmed as allowable business expenses without TDS.
ITAT Delhi set aside reassessment because notices under Sections 148, 148A(b), and 148A(d) lacked digital or manual signatures. Procedural lapses can invalidate reassessments entirely.
The appellate orders for AY 2012-13 & 2013-14 were set aside as the deceased assessee was not heard. The legal heir is now allowed to present documents and have the appeal adjudicated afresh.
