The Tribunal held that once business receipts are taxed on an estimated basis, separate additions for payments and assets from the same receipts are impermissible. Only a net-profit estimation was sustained, deleting multiple cascading additions.
The tribunal accepted that allotment confers enforceable capital rights capable of transfer. The ruling clarifies that proceeds from such transfers must be assessed under capital gains, not deemed income.
The Tribunal found that indexation was wrongly applied from a later year. It held that long-term capital gains must be computed from the first year the property was held.
The Tribunal ruled that when purchases are disallowed as non-genuine without questioning the source of payment, section 69C cannot be invoked. A plausible disallowance under section 37(1) cannot be revised under section 263 merely to change the charging provision.
ITAT Mumbai quashed reassessment for AY 2017-18 as notice issued after three years lacked mandatory sanction under Section 151(ii), holding approval by Pr.CIT insufficient under post-2021 law.
The Supreme Court held that the inclusion of a tainted official in the selection committee created a reasonable apprehension of bias. The key takeaway is that even one biased member vitiates the entire selection process.
The Tribunal confirmed deletion of additions where the AO made no effort to verify consignees, transporters, or stock movement. Proper documentation and bank-received sale proceeds proved transaction genuineness.
The issue was whether section 68 could be invoked for alleged on-money payments absent direct evidence. The Tribunal ruled that in the absence of corroborative material, the addition must be deleted.
The issue was whether the full value of alleged bogus purchases could be added to income. The Tribunal upheld that only the profit element embedded in such purchases is taxable, not the entire purchase value.
The Court ruled that a marginal eight-minute delay in filing the return could not justify denial of loss carry forward. The order rejecting condonation was set aside to prevent disproportionate hardship.
