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The Tribunal granted permission to the assessee to withdraw the appeal, as the assessee had received the requisite relief from the PCIT's order under Section 263 and the subsequent assessment order. The appeal was therefore dismissed as withdrawn.
The Tribunal held that the disallowance of shutdown wages was unjustified as the assessee had earned revenue from manpower supply during shutdown activities. Minor deficiencies in wage registers should not lead to disallowance of entire wages, especially when accounts are audited.
The Tribunal held that the disallowance of shutdown wages was unjustified as the assessee had earned revenue from manpower supply during shutdown activities. Minor deficiencies in wage registers should not lead to disallowance of entire wages, especially when accounts are audited.
The Tribunal held that the disallowance of shutdown wages was unjustified as the assessee had earned revenue from manpower supply during shutdown activities. Minor deficiencies in wage registers should not lead to disallowance of entire wages, especially when accounts are audited.
The Tribunal held that the disallowance of shutdown wages was unjustified as the assessee had earned revenue from manpower supply during shutdown activities. Minor deficiencies in wage registers should not lead to disallowance of entire wages, especially when accounts are audited.
The Tribunal held that the disallowance of shutdown wages was unjustified as the assessee had earned revenue from manpower supply during shutdown activities. Minor deficiencies in wage registers should not lead to disallowance of entire wages, especially when accounts are audited.
The Tribunal held that the assessee had the option to choose a valuation method under Rule 11UA and had substantiated its valuation using the market/stamp duty value of land. The AO could not impose his own valuation method without disproving the assessee's claim. Therefore, the addition made by the AO was deleted.
The Tribunal held that the fresh notice under Section 148 was invalid because the prior approval was taken from the PCIT instead of the PCCIT/PDGIT or CCIT, violating Section 151(ii) of the Act. Additionally, the notice was barred by limitation as it was issued beyond the three-year period.
The Tribunal held that the amended provisions of Section 115BBE, effective from December 15, 2016, cannot be applied retrospectively to income surrendered during a survey conducted on August 23, 2016. Since the surrendered income was explained as business income, the pre-amendment tax rate of 30% is applicable, and the application of Section 115BBE and Sections 68-69D was unjustified.
The Tribunal found the JCIT(A) was not justified in rejecting the appeal on technical grounds and confirming the entire receipts as income. It held that the assessee's claim for allowing corresponding expenditure against receipts was justified. The matter was remanded to the Assessing Officer to treat the assessee as an AOP and allow legitimate expenses after due verification.
The Tribunal found that the AO and CIT(A) failed to provide the assessee with an opportunity to explain the inquiries made with the creditors, violating Section 142(3) and CBDT SOP. It noted that transactions were through banking channels and three creditors had explained their sources. Citing a Rajasthan High Court judgment, the Tribunal ruled that depositing cash before transferring a loan is not sufficient grounds for an addition under Section 68. Therefore, the addition was deleted.
The Tribunal held that the AO's addition was based on doubts and assumptions, and the assessee had discharged their primary burden by providing evidence of identity, capacity of lenders, and genuineness of the transaction. The Tribunal also noted that a similar loan to a family member was accepted as genuine. Therefore, the addition was deleted.
The tribunal deleted the disallowance of rebate expenses, finding them genuine and interlinked with rebate income. For the unsecured loans and interest expenses, the tribunal admitted additional evidence and remanded the matter back to the AO for fresh adjudication, granting the assessee another opportunity to be heard.
The Tribunal found that the CIT(A) erred in dismissing the appeal ex-parte without adequately considering the assessee's prior submissions to the AO and without issuing a show cause notice. It held that the assessee was denied a fair opportunity to be heard and that the assessment order might be invalid due to the lack of a draft assessment order. The case was remanded to the AO for a de novo assessment.
The tribunal reduced the sustained trading addition by applying a 2% net profit rate on the total turnover, resulting in an additional net profit of Rs. 8,32,481/- to be taxed. It also held that Section 115BBE would not apply as the addition was estimated without specific concealment or evasion.
The Tribunal held that the cash deposits belonged to the AOP, M/s Om Prakash Saurabh Tak & Party, and were accounted for in the AOP's books, which had been assessed by the AO. Since the department failed to disprove this, the addition made under Section 68 in the assessee's hands was deleted.
The Tribunal upheld the CIT(A)'s decision, finding that the stock valuation was justified based on accounting principles for damaged goods, and the cash deposits were explained by the assessee's relocation due to bank possession and the nature of their cash-rich business.
The Tribunal held that the CIT(A) lacked the jurisdiction to reject the books of account when the Assessing Officer had not proposed to do so and had accepted the assessee's accounting method. The Tribunal also found the addition under Section 69A to be perverse to the facts.
The Tribunal held that the disallowance of shutdown wages was unjustified as the assessee had earned revenue from manpower supply during shutdown activities. Minor deficiencies in wage registers should not lead to disallowance of entire wages, especially when accounts are audited.
The Tribunal held that the AO was not justified in rejecting the books of accounts and making additions without providing the assessee an opportunity to cross-examine third-party evidence. The Tribunal emphasized that the department must provide an opportunity to controvert evidence relied upon.
The Tribunal held that the CIT(A) was not justified in rejecting the assessee's submissions and confirming the additions. The Tribunal found that the depositors were income tax payers, provided confirmations, ledger accounts, and bank statements, and that the transactions were through banking channels. The addition of Rs. 2,96,50,000 was directed to be deleted.
The Tribunal held that once an assessment order merges with an appellate order or is finalized under the Vivad Se Vishwas Scheme, the PCIT cannot exercise revisional jurisdiction under Section 263. The order passed by the PCIT under Section 263 was deemed bad in law, illegal, and void ab initio.
The ITAT held that the CIT(A) violated principles of natural justice by admitting new evidence and granting relief without forwarding the evidence to the AO for a remand report. The matter was remanded back to the AO for a de novo assessment.
The Tribunal found the CIT(A)'s ex-parte order arbitrary and in violation of natural justice. It remanded the case back to the CIT(A) to re-adjudicate the issue after providing the assessee a proper opportunity to be heard and considering all submissions.
The Tribunal held that the AO erred by ignoring the assessee's books of accounts, which were accepted, and by not examining the purchase and sales invoices. It found that the AO failed to establish that the cash deposits were unexplained or from activities other than declared business. The assessment order was also deemed invalid due to the AO's failure to issue a show cause notice.
The Tribunal found that the CIT(A) did not properly consider the assessee's submissions, which indicated that the acquisition of assets was not treated as an application of income in previous years. Therefore, the matter was remanded to the AO for fresh verification of the depreciation claim under Section 11(6) of the Income Tax Act.
The tribunal held that merely enabling a communication window on the portal could not be construed as granting an opportunity of being heard. It found that the CIT(A) violated natural justice by not providing adequate opportunity to the assessee over a three-year period before passing the order. Therefore, the matter was remanded back to the CIT(A) for a fresh decision on merits after granting proper opportunity.
The Tribunal held that the amendment to Section 200A, which enables the levy of fee under Section 234E, is prospective from June 1, 2015. Since the TDS in question related to a period prior to this date, the levy of fee and interest was without legal authority and therefore illegal and invalid. The Tribunal deleted the fee and interest.
The Tribunal noted that the assessees had withdrawn their registration applications before the CIT(E). Consequently, the appeals filed against the rejection of these withdrawn applications were deemed not maintainable.
The Tribunal found that the CIT(A) did not properly consider the assessee's submissions, which indicated that the acquisition of assets was not treated as an application of income in previous years. Therefore, the matter was remanded to the AO for fresh verification of the depreciation claim under Section 11(6) of the Income Tax Act.
The tribunal directed the Assessing Officer to examine and verify the contents of Form 26AS and allow credit for the TDS mismatch, if any, to the assessees. It noted that Kachha Arhatias act as agents, and only their gross commission should be considered as turnover, not the sale value of crops belonging to farmers.
The tribunal directed the Assessing Officer to examine and verify the contents of Form 26AS and allow credit for the TDS mismatch, if any, to the assessees. It noted that Kachha Arhatias act as agents, and only their gross commission should be considered as turnover, not the sale value of crops belonging to farmers.
The tribunal directed the Assessing Officer to examine and verify the contents of Form 26AS and allow credit for the TDS mismatch, if any, to the assessees. It noted that Kachha Arhatias act as agents, and only their gross commission should be considered as turnover, not the sale value of crops belonging to farmers.
The tribunal directed the Assessing Officer to examine and verify the contents of Form 26AS and allow credit for the TDS mismatch, if any, to the assessees. It noted that Kachha Arhatias act as agents, and only their gross commission should be considered as turnover, not the sale value of crops belonging to farmers.
The tribunal directed the Assessing Officer to examine and verify the contents of Form 26AS and allow credit for the TDS mismatch, if any, to the assessees. It noted that Kachha Arhatias act as agents, and only their gross commission should be considered as turnover, not the sale value of crops belonging to farmers.
The tribunal directed the Assessing Officer to examine and verify the contents of Form 26AS and allow credit for the TDS mismatch, if any, to the assessees. It noted that Kachha Arhatias act as agents, and only their gross commission should be considered as turnover, not the sale value of crops belonging to farmers.
The tribunal directed the Assessing Officer to examine and verify the contents of Form 26AS and allow credit for the TDS mismatch, if any, to the assessees. It noted that Kachha Arhatias act as agents, and only their gross commission should be considered as turnover, not the sale value of crops belonging to farmers.
The Tribunal held that the CIT (Exemption) acted in haste by rejecting the applications, especially since the RPT Act registration was pending and subsequently granted. Following a similar precedent, the Tribunal remanded the matters back to the CIT (Exemption) for fresh adjudication, directing that the assessees be given an adequate opportunity to be heard and to furnish necessary details regarding their activities.
The Tribunal held that the CIT (Exemption) acted in haste by rejecting the applications, especially since the RPT Act registration was pending and subsequently granted. Following a similar precedent, the Tribunal remanded the matters back to the CIT (Exemption) for fresh adjudication, directing that the assessees be given an adequate opportunity to be heard and to furnish necessary details regarding their activities.
The Tribunal held that the CIT (Exemption) acted in haste by rejecting the applications, especially since the RPT Act registration was pending and subsequently granted. Following a similar precedent, the Tribunal remanded the matters back to the CIT (Exemption) for fresh adjudication, directing that the assessees be given an adequate opportunity to be heard and to furnish necessary details regarding their activities.
The Tribunal noted that the assessees had withdrawn their registration applications before the CIT(E). Consequently, the appeals filed against the rejection of these withdrawn applications were deemed not maintainable.
The Tribunal held that the CIT (Exemption) acted in haste by rejecting the applications, especially since the RPT Act registration was pending and subsequently granted. Following a similar precedent, the Tribunal remanded the matters back to the CIT (Exemption) for fresh adjudication, directing that the assessees be given an adequate opportunity to be heard and to furnish necessary details regarding their activities.
The Tribunal held that the CIT (Exemption) acted in haste by rejecting the applications, especially since the RPT Act registration was pending and subsequently granted. Following a similar precedent, the Tribunal remanded the matters back to the CIT (Exemption) for fresh adjudication, directing that the assessees be given adequate opportunity to present their case and provide necessary details regarding their activities.
The Tribunal set aside the CIT (Exemption)'s order, remanding the matter for fresh adjudication. It directed the CIT (Exemption) to re-examine the applications for registration under Section 12AB and approval under Section 80G, considering the subsequent registration under the RPT Act and allowing the assessees to furnish further details regarding their activities.
The tribunal directed the Assessing Officer to examine and verify the contents of Form 26AS and allow credit for the TDS mismatch, if any, to the assessees. It noted that Kachha Arhatias act as agents, and only their gross commission should be considered as turnover, not the sale value of crops belonging to farmers.
The Tribunal dismissed the Revenue's appeal due to low tax effect, as the disputed amount was below the mandatory limit of Rs. 60,00,000 set by CBDT Circular No. 9 of 2024. Consequently, the assessee's cross-objection was rendered infructuous.
The assessee's counsel requested to withdraw the appeal because the assessee had reapplied for registration and was subsequently granted registration under Section 12AB on 27.09.2025. The Ld. DR had no objection, and thus the appeal was dismissed as withdrawn.