The issue was whether stamp duty value of redevelopment property is taxable without possession. ITAT held that Section 56(2)(x) applies only on actual receipt, so no tax arises without possession.
The Tribunal upheld reduced addition as earlier years’ rulings fixed profit element at 0.2%. It stressed that consistent facts require consistent treatment. Key takeaway: uniform approach must be followed across years.
ITAT Pune deletes ₹4.83 lakh penalty under Section 271(1)(c), holding that a bona fide difference in share valuation methods (NAV vs DCF) does not amount to furnishing inaccurate particulars; mere rejection of a claim cannot trigger penalty.
The Tribunal deleted the addition under Section 69A since the evidence pertained to a partnership firm. It held that without proof of personal receipt, income cannot be taxed in the partner’s hands.
The ruling confirms that additions cannot be made merely on suspicion without supporting material. The Court found that the Assessing Officer did not bring any evidence to disprove the assessee’s transactions.
The Tribunal held that loans received from NBFCs cannot be treated as unexplained where identity, creditworthiness, and genuineness are established. Absence of incriminating material led to deletion of additions.
The Tribunal held that the addition of ₹8.44 crore was unsustainable as it was based on incorrect assumptions about multiple bank accounts. It ruled that properly recorded and explained transactions cannot be treated as unexplained income under Section 69A.
The case examined whether scrutiny selection without meeting CBDT conditions was valid. The ITAT held that failure to satisfy mandatory criteria invalidated the notice and entire assessment.
The Tribunal upheld relief where the assessee provided proof of agricultural activities and income. It rejected additions based solely on statements without investigation. The case underscores the importance of documentary support.
ITAT Mumbai deleted Section 69 addition on alleged on-money, holding third-party statements and unverified pen drive data lack evidentiary value without corroboration or cross-examination, upholding natural justice.
