The Tribunal observed that ₹99.10 lakh allegedly added as unexplained credits may represent earlier year balances. The matter was remanded for verification to avoid wrongful taxation in the current assessment year.
ITAT ruled that a 76/23 split in chats reflected proposed refurbishment costs, not undisclosed cash consideration. In absence of corroborative material, addition under Sections 69 and 115BBE was held unsustainable.
The Tribunal emphasized that approval from the correct specified authority is mandatory where reopening exceeds three years. Failure to comply rendered the reassessment proceedings void ab initio.
Observing that the assessee invested the entire share of sale proceeds within two years and obtained possession, ITAT Pune allowed Section 54B exemption. The addition under Section 69A was consequently deleted.
ITAT Mumbai held that even if Section 11 exemption is denied due to lack of registration, the Assessing Officer cannot tax entire gross receipts without examining expenditure. Only net income, if any, can be brought to tax.
The High Court set aside a tax demand arising from foreign tax credit mismatch because no valid intimation under Section 143(1) was produced or served. It held that recovery cannot be enforced without mandatory service of notice of demand.
The Tribunal held that year of acquisition is determined by payment and handing over of possession under Section 2(47)(v), not by later registration date. Earlier CII was allowed for capital gains computation.
The Tribunal ruled that the Assessing Officer must prove actual possession of unexplained money with cogent evidence. Mere suspicion or reliance on third-party search statements is insufficient to justify addition under Section 115BBE.
The Court ruled that GST proceedings initiated under Section 74 for FY 2024–25 were without jurisdiction and directed treatment of the order as a Section 74A notice.
The Tribunal held that capital gains must be computed using the final stamp value determined after litigation, not an earlier inflated valuation, and directed deletion of the resulting addition.
