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The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal held that the transactions, though involving a penny stock, were conducted through a registered broker with payments via banking channels and STT paid. The addition on account of LTCG was deleted, but the addition for unexplained bank credits was upheld.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal upheld the orders of the CIT(A), holding that additions made under Section 153A without incriminating material found during search are not sustainable. The Tribunal dismissed all appeals filed by the Revenue.
The Tribunal held that the transactions, though involving a penny stock, were conducted through a registered broker with payments via banking channels and STT paid. The addition on account of LTCG was deleted, but the addition for unexplained bank credits was upheld.
Considering the principles of natural justice, the Tribunal condoned the delay and restored both appeals to the file of the CIT(A) for a de novo adjudication on merits. The assessee was directed to present and prove its case before the CIT(A) forthwith. The appeals were allowed for statistical purposes.
The Tribunal held that the assessee discharged the onus to prove genuineness of purchases with audited books, VAT returns, bank payments, confirmed ledger, and delivery receipts. The sole basis for the addition was a third-party statement, but no corroborating incriminating material was found, and the assessee was denied cross-examination, violating principles of natural justice. Therefore, the addition was unsustainable.
Considering the principles of natural justice, the Tribunal condoned the delay and restored both appeals to the file of the CIT(A) for a de novo adjudication on merits. The assessee was directed to present and prove its case before the CIT(A) forthwith. The appeals were allowed for statistical purposes.
The Tribunal, applying principles of natural justice despite the assessee's negligence, admitted the quantum appeal and restored both appeals to the CIT(A) for de novo adjudication. The assessee was directed to present and prove its case forthwith before the CIT(A).
The Tribunal held that loose sheets alone, without corroborative evidence, cannot fix liability. It also found that non-production of a stock register alone is not sufficient to reject book results when audited accounts show satisfactory net profit rates.
The Tribunal, applying principles of natural justice despite the assessee's negligence, admitted the quantum appeal and restored both appeals to the CIT(A) for de novo adjudication. The assessee was directed to present and prove its case forthwith before the CIT(A).
The Tribunal held that the assessee discharged the onus to prove genuineness of purchases with audited books, VAT returns, bank payments, confirmed ledger, and delivery receipts. The sole basis for the addition was a third-party statement, but no corroborating incriminating material was found, and the assessee was denied cross-examination, violating principles of natural justice. Therefore, the addition was unsustainable.
The Tribunal found that the assessee, being a State Government Undertaking, did not exhibit willful default or neglect, and the delay was attributable to incorrect professional advice. In the interest of justice, the Tribunal condoned the delay of 1004 days and remanded the matter back to the FAA for adjudication on the merits of the various issues raised. The Tribunal did not express any opinion on the merits of the case itself.
The Tribunal held that once business profits are estimated on a fair percentage of gross sales, separate additions under Section 68 for unsecured loans and partner's capital, as reflected in a draft return, cannot be sustained. The Tribunal deleted these additions.
The Ld. DR conceded that the tax effect was below the threshold and that the case did not fall under any exceptions. The Tribunal, citing CBDT Circular No. 09 of 2024, dismissed the revenue's appeal as not maintainable since the tax effect was below the monetary limit for filing appeals before the Income Tax Appellate Tribunal.
The Tribunal observed that the new documentary evidence, including bank statements and certificates from private lenders, required verification by the Assessing Officer. Therefore, in the interest of justice, the matter was remanded back to the AO for fresh assessment to consider all submitted documentary evidence concerning the loans and to allow the assessee a reasonable opportunity to explain the source of cash. The Tribunal did not express any opinion on the merits of the case, leaving all issues open for reconsideration.
The Tribunal found that the legal issues concerning the AO's jurisdiction were vital and unaddressed by the CIT(A). Therefore, the Tribunal set aside the CIT(A)'s order and restored the appeal to the file of the Ld. CIT(A) for fresh adjudication on both legal grounds and merits.
The Tribunal, acknowledging the assessee's negligence but upholding principles of natural justice, restored the appeal to the file of the Ld. CIT(A) for a de novo adjudication. The assessee was directed to appear and prove its case without delay.
The Tribunal set aside the impugned orders and remanded the matter back to the CIT(E). It directed the CIT(E) to decide the applications afresh after affording a proper opportunity of hearing to the assessee to present its case. The rejection of 80G approval was also restored to the CIT(E) for similar consideration.
The Tribunal set aside the impugned orders and remanded the matter back to the CIT(E). It directed the CIT(E) to decide the applications afresh after affording a proper opportunity of hearing to the assessee to present its case. The rejection of 80G approval was also restored to the CIT(E) for similar consideration.
The Tribunal held that the notice issued under Section 148 by the Jurisdictional Assessing Officer (JAO) on 29-03-2023 was invalid, as it should have been issued by a Faceless Assessing Officer (FAO) as mandated by Section 151A and relevant notifications. Relying on the precedent set by the Punjab & Haryana High Court, the Tribunal quashed the impugned notice and allowed the appeal.
Despite the assessee's negligence and non-appearance, the tribunal admitted the appeal based on principles of natural justice. The case was restored to the CIT(A) for de novo adjudication, with a direction for the assessee to present and prove its case forthwith.
The Tribunal, citing principles of natural justice, set aside the impugned order and remanded the matter back to the Ld. CIT(A) for reconsideration. The CIT(A) is directed to examine the fresh evidences submitted by the assessee, and the assessee is required to present and prove its case forthwith.
The Tribunal condoned the delay, finding the assessee's grievance genuine due to the typographical error in the addition and additional explained sources of funds. It directed the AO to delete the entire Rs. 29 Lacs addition in full.
The Tribunal condoned the assessee's 32-day delay in filing the appeal to the ITAT, noting his medical condition. It then remanded the case back to the Assessing Officer for a fresh assessment, instructing the AO to provide the assessee a reasonable opportunity to present documentary evidence to establish his business and explain the source of the cash deposits. The Tribunal directed the AO to issue notice as per Section 282.
The Tribunal condoned the delay in filing the appeal due to the assessee's medical condition. Regarding the merits, the Tribunal noted the lack of crucial documentary evidence from the assessee, such as the relinquishment agreement from Mr. Vikas Sharma or the direct sale deed. Due to conflicting claims and insufficient evidence, the Tribunal remitted the matter back to the Assessing Officer for a limited purpose, directing the assessee to provide necessary documentary evidence to prove his contention that the land was purchased from Mr. Vikas Sharma in April 2012 and that Mr. Sharma incurred the expenses.
The Tribunal found that the paper book submitted by the assessee was disorganized and lacked proper indexing, making it difficult to understand the case. Due to the unusual circumstances and the lack of clarity, the Tribunal set aside the matter back to the CIT(A) for fresh adjudication.
The Tribunal accepted the assessee's request for withdrawal, noting that the Ld. DR had no objection. Consequently, the appeal filed by the assessee was dismissed as withdrawn. The order was pronounced in accordance with Rule 34(4) of the Income Tax (Appellate Tribunal) Rules, 1963.
The Tribunal found that the CIT(A) erred in dismissing the appeal without providing the assessee an opportunity to explain the actual service date of the assessment order or to justify the delay. In the interest of justice, the Tribunal remanded the case back to the CIT(A), directing them to grant a reasonable opportunity to the assessee to prove the date of receipt and then to adjudicate the appeal on its merits.
The Tribunal held that the addition of Rs. 11.50 lakhs, representing cash deposited in the alleged donor's bank account, could not be taxed in the hands of the assessee as there was no direct evidence that the assessee had provided these funds. The Tribunal also noted that while the gifts were bogus, no addition was made by the Assessing Officer on that ground.
The Tribunal condoned the delay in filing the appeal, noting that notices were not properly served on the assessee's email. It remanded the case back to the first appellate authority for a fresh adjudication on merits, allowing the assessee an opportunity to present evidence.
The Tribunal condoned the delay in filing the appeal, noting that notices were not properly served on the assessee's email. It remanded the case back to the first appellate authority for a fresh adjudication on merits, allowing the assessee an opportunity to present evidence.