The ITAT ruled a reassessment under Section 147 invalid because the Assessing Officer failed to issue the mandatory Section 143(2) notice. compliance with notice requirements is crucial for valid reassessment.
The Tribunal held that unexplained money addition cannot stand when the AO ignores direct verification from the bank. Matter restored to the AO to summon the bank and tax only actual interest income.
The Tribunal held that agricultural income cannot be disallowed merely due to a year-on-year increase. Since land ownership, crop details, and receipts were undisputed, the addition was deleted.
The Tribunal condoned a 960-day delay after finding that the assessee’s reliance on VSV settlement and pending rectification was a bona fide cause. It ruled that penalty under Section 271D is independent of quantum proceedings. The penalty appeal was wrongly dismissed as infructuous and has been remanded for fresh decision.
The Tribunal found that a fixed-deposit mismatch caused an unjustified ₹5.33-crore addition. Delay was condoned and the matter was remanded for fresh assessment with proper verification.
The Tribunal accepted that the 7.5% rebate was a pre-negotiated commercial discount and not an unaccounted cash return. As the seized loose sheets were unverified and unsupported by witnesses, the ₹9.06 crore addition failed.
Incorrect Form 3CD reporting led CPC to treat rental income and capital gains as business income. The Tribunal ruled that such mismatches cannot justify additions without verification.
The Tribunal ruled that interest from co-operative bank deposits is attributable to business activity and eligible for deduction under Section 80P(2)(a)(i). The disallowance of ₹8.98 lakh was ordered to be deleted.
ITAT Chennai held that a Section 148 notice issued by JAO after 29.03.2022 is invalid, as the faceless assessment scheme is mandatory, nullifying the reassessment order.
ITAT Kolkata ruled that cash advances discovered during a survey must be assessed as business income, not unexplained cash credit under Section 68, making the exercise tax-neutral.
