ITAT Mumbai Judgments — August 2025

The Tribunal held that interest under Section 234A cannot be levied for a period subsequent to the full discharge of self-assessment tax liability, especially when the return is filed within the extended due date granted by the CBDT, irrespective of the tax payable amount exceeding Rs. 1 lakh.

The Tribunal held that the reassessment proceedings were bad in law due to the non-supply of reasons recorded for reopening the assessment to the assessee. The Tribunal noted that the assessee had explicitly requested the reasons in its letter dated 04.04.2017, which were not provided. Relying on the decision of the Hon'ble Bombay High Court in IDBI Ltd. and CIT v. Videsh Sanchar Nigam Ltd., and a coordinate bench decision in DCIT vs Bhawna Computers (P.) Ltd., the Tribunal concluded that the assessment made under section 147 r.w.s. 143(3) without communicating the reasons is invalid. The Tribunal found that the assessee's participation in the proceedings did not negate the prejudice caused by the non-supply of reasons, as it deprived the assessee of the fundamental right to object. Consequently, the assessment orders were quashed, and the appeal of the assessee was allowed. The Tribunal considered it unnecessary to adjudicate the grounds on merits.

The Tribunal condoned the delay in filing the appeal after noting the Ld. DR did not object. It was observed that the assessee relied on a legal consultant who defaulted in compliance. The matter was restored to the AO for fresh adjudication.

The Tribunal found that the DVO's report was crucial evidence that was not considered by the AO at the time of assessment. Therefore, the matter was remitted back to the AO to consider the DVO's report and pass a speaking order.

The Tribunal found that the DVO's report was crucial evidence that was not considered by the AO at the time of assessment. Therefore, the matter was remitted back to the AO to consider the DVO's report and pass a speaking order.

The Tribunal held that the Assessing Officer's additions were based solely on general investigation reports without specific evidence linking the assessee's transactions to bogus activities. The assessee had provided sufficient documentary evidence to substantiate the genuineness of the loans and purchases.

The Tribunal held that the Assessing Officer's additions were based solely on general investigation reports without specific evidence linking the assessee's transactions to bogus activities. The assessee had provided sufficient documentary evidence to substantiate the genuineness of the loans and purchases.

The Tribunal held that the Assessing Officer's additions were based solely on general investigation reports without specific evidence linking the assessee's transactions to bogus activities. The assessee had provided sufficient documentary evidence to substantiate the genuineness of the loans and purchases.

The Tribunal noted that new explanations and documents were presented by the assessee for the first time. Consequently, the Tribunal restored the issues related to undisclosed business profit, income from other sources, and long-term capital gains to the AO for fresh consideration.

On the issue of disallowance of bad debts written off (Issue 1), the Tribunal, following the co-ordinate bench decision in The Karnataka Bank Ltd. vs. DCIT, held that the bad debts relating to non-rural branches are also required to be first adjusted against the provision for bad and doubtful debts (PBDD) account. The deduction under Section 36(1)(vii) is limited to the amount by which the debt exceeds the credit balance in the PBDD account under Section 36(1)(viia). The Tribunal noted that Explanation 2 to Section 36(1)(vii) clarifies that the PBDD account relates to all types of advances, including those by rural branches. Therefore, the disallowance made by the AO and confirmed by the CIT(A) was upheld, and the assessee's ground was dismissed. Regarding the applicability of Section 115JB (Issue 2), the Tribunal held that the provisions of Section 115JB are not applicable to the assessee, which is established by the Banking (Companies Transfer of Undertakings) Act, 1970, and not under the Companies Act, following the decision in UCO Bank. Consequently, grounds related to adjustment in book profit for disallowance under Section 14A and addition of provisions to income while computing book profit became infructuous. On the issue of disallowance under Section 14A read with Rule 8D (Issue 3), the Tribunal, respectfully following the co-ordinate bench decision in the assessee's own case, directed the AO to delete the disallowance, as exempt income was earned on shares/stock held as 'stock-in-trade'.

The Tribunal held that the PCIT erred in invoking revisionary jurisdiction under section 263. Firstly, the issue of disallowance of purchases was already the subject matter of appellate proceedings before the CIT(A). The Tribunal cited the principle that an appellate authority has all the powers of the original authority, and the PCIT could not re-adjudicate the matter from a different perspective under revisionary jurisdiction. Secondly, the Tribunal distinguished between 'lack of inquiry' and 'inadequate inquiry', citing the Delhi High Court in CIT Vs. Sunbeam Auto and the Bombay High Court in Gabriel India Ltd. The AO had made inquiries, and the PCIT could not impose his own understanding of the extent of inquiry. The Tribunal noted that where two views are possible, and the AO has taken a plausible view, it cannot be treated as erroneous unless unsustainable in law or demonstrating non-application of mind. The PCIT's view that purchases reflected in books could be brought under section 69C was also debatable. The Tribunal set aside the PCIT's order. The issue of penalty proceedings was also noted as something the PCIT could not direct the AO to initiate differently.

The Tribunal held that regular books of accounts cannot be treated as incriminating material for assessment under Section 153A. For AY 2015-16 and 2016-17, the assessment orders were quashed as the limitation period for issuing notices under Section 143(2) had expired before the search. For AY 2017-18, the issue of sales returns was restored to the AO for fresh examination.

The Tribunal addressed several grounds. For Ground No. 6 concerning the foreign currency translation difference of Rs. 37,64,61,452, the Tribunal found that the details were not duly examined by the AO and the CIT(A) did not clarify the factual position. Therefore, the matter was remitted back to the AO for verification after affording the assessee an opportunity of being heard. This ground was allowed for statistical purposes. For Grounds 7 to 9, relating to the disallowance of carry forward of Long-Term Capital Loss of Rs. 28,16,96,948 on sale of STT-paid shares, the Tribunal considered the AO's disallowance and the CIT(A)'s reasoning. While acknowledging that Section 10(38) excludes income, not the computation of losses, the CIT(A) upheld the disallowance due to concerns about future set-off against unrelated gains and verification difficulties. The Tribunal found the CIT(A)'s decision to be reasoned and well-founded, noting no infirmity. Accordingly, this ground was dismissed. The remaining grounds for AY 2016-17 were identical and disposed of accordingly. The appeals were partly allowed.

The Tribunal held that the Assessing Officer's additions were based solely on general investigation reports without specific evidence linking the assessee's transactions to bogus activities. The assessee had provided sufficient documentary evidence to substantiate the genuineness of the loans and purchases.

The Tribunal held that the assessee had a reasonable cause for not furnishing the details as required by Rule 10D, considering the complexities of the diamond trade. The Tribunal noted that similar penalties had been deleted in the assessee's own cases and by coordinate benches.

The Tribunal found that the CIT(A) erred in deleting the additions without sufficient justification, overlooking the AO's findings about the lack of evidence. The appellate order was set aside for fresh consideration.

The Tribunal noted that the DVO's report was a crucial piece of evidence that ought to have been considered while passing the assessment order. However, the report was not available before the AO at the time of framing the assessment for AY 2014-15, and for AY 2016-17, the assessment order was made subject to the DVO's report. Subsequently, the DVO's report was received and made available to both parties. In the interest of justice, the Tribunal found it appropriate to remit the matter back to the file of the AO. The AO is directed to consider the DVO's report and thereafter pass a speaking order giving effect to such report. The assessee will be afforded a reasonable opportunity of being heard, and any documentary evidence or material sought to be filed by the assessee in the set-aside proceedings shall be admitted in accordance with law. The Tribunal expressly left undecided the ultimate tax liability, as it was remitted for fresh adjudication.

The Tribunal dismissed all appeals filed by the Revenue. For the assessee's appeals, they were partly allowed. The Tribunal found that the Revenue's grounds of appeal concerning the deletion of additions under Section 69A (Rs. 12,35,30,000/-) and Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were dismissed as discussed in previous paragraphs (para 56 and 32-55 respectively). The assessee's ground regarding the invocation of Section 115BBE was allowed based on findings in para 56. The assessee's ground regarding directions to calculate peak of unrelated transactions was allowed based on findings in para 35. The assessee's grounds concerning additions under Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were partly allowed based on findings in para 32-55. The Tribunal's reasoning for dismissing the Revenue's appeals and partly allowing the Assessee's appeals is detailed in the preceding paragraphs of the judgment, which are not fully reproduced here. The operative direction is that the Revenue's appeals are dismissed, and the Assessee's appeals are partly allowed.

The Tribunal held that the reassessment order passed by the Assessing Officer was barred by limitation. Consequently, the reassessment order was set aside.

The Tribunal held that the impugned order passed by the Ld. CIT(A) suffered from illegality and miscarriage of justice due to the failure to provide an effective opportunity of hearing to the assessee, which is a violation of the principles of natural justice. The Tribunal noted that while five notices were issued to the assessee, there was no evidence of their proper service, and the short notice period of seven days in the last notice was insufficient for a reply. The Tribunal referred to Section 250(2)(a) of the Act, emphasizing that a hearing is not a mere formality but an effective one. Consequently, the Tribunal set aside the impugned order and restored the matter to the file of the Ld. CIT(A) for fresh adjudication, directing that the assessee be given an effective opportunity of hearing and be allowed to present its case within 60 days. The appeal was allowed for statistical purposes.

The Tribunal held that the reassessment order passed by the Assessing Officer was barred by limitation. Consequently, the reassessment order was set aside.

The Tribunal held that the long-term capital gains declared by the assessee could not be doubted. It noted that the assessee purchased shares through a broker on the stock exchange platform, paid consideration through banking channels, held the shares for more than a year, and sold them through the same platform. The assessee furnished all supporting documents, and the AO did not examine them to find fault. The shares entered and exited the assessee's DEMAT account. The Tribunal found that the assessee was not dealing with the Vipul Vidur Bhatt group and invested as an ordinary investor, not part of any price rigging ring. The Tribunal relied on the jurisdictional Bombay High Court decisions in PCIT vs. Shyam R Pawar (though not fully quoted in the provided text, it's referenced as 'supra'), PCIT vs. Ziauddin A. Siddique, and PCIT vs. Indravadan Jain, HUF, which dealt with similar transactions of penny stocks bought and sold through stock exchanges via registered brokers, with payments through banking channels and STT paid. The Tribunal concluded that the AO was not justified in assessing the sale value of shares as unexplained cash credit under Section 68. Consequently, the addition relating to capital gains was deleted, and the consequential addition of estimated expenses was also deleted. The appeal was allowed.

The Tribunal held that the CIT(A) had erred in deleting the disallowance of Rs.1,47,19,272/- made under Section 37(1) for AY 2013-14. The Tribunal found that the assessee had failed to substantiate the allowability of these expenses and could not provide a satisfactory explanation for the presence of signed blank cheque books of parties at the employee's premises. Furthermore, the reconciliation documents relied upon by the CIT(A) were not produced before the Assessing Officer. The Tribunal also found that the deletion of the addition made in respect of unsecured loans from Meenu Sharma was erroneous as the assessee failed to furnish evidence to establish the creditworthiness and genuineness of the transaction. The Tribunal directed the AO to re-examine these issues. Regarding the additions based on the seized diaries, the Tribunal noted that the CIT(A) had restricted the addition based on peak credit balance. The Tribunal found that the AO had made elaborate efforts to correlate the diary entries with other evidence. However, the Tribunal also acknowledged the assessee's contention regarding Jiten Pujari's retraction and the issue of digital evidence under Section 65B of the Indian Evidence Act. The Tribunal decided to remand these issues back to the AO for fresh adjudication, directing the AO to consider the evidence holistically, including the retracted statement, digital evidence with proper certification, and any other corroborative material, and to decide the matter afresh after providing the assessee with an opportunity of being heard. The issue regarding assessment beyond six years was also remanded for fresh consideration.

The Tribunal held that the additions made by the Assessing Officer based on seized diaries and digital evidence were partly confirmed and partly deleted. The Tribunal also addressed grounds related to commission, unsecured loans, and unexplained expenditures.

The ITAT condoned the delay in filing the appeal, finding reasonable cause for the assessee's non-compliance. The tribunal allowed the assessee to place the purchase agreement on record and remanded the matter back to the Assessing Officer for fresh examination, verification, and a report from the DVO, ensuring the assessee is provided a reasonable opportunity.

The Tribunal noted that the primary issue revolved around the evidentiary value of the diaries seized from Shri Jiten Pujari. The assessee argued that the diaries were mere jottings and that Shri Pujari's initial statement was retracted. The revenue contended that the diaries, corroborated by other evidence, constituted alternate books of account. The Tribunal observed that the AO had made additions based on the diary entries, and the CIT(A) had restricted these additions based on peak credit balance. The Tribunal also considered the revenue's grounds regarding commission rates and the assessee's grounds concerning additions based on third-party evidence and retracted statements. The Tribunal acknowledged the assessee's argument that no incriminating documents were found at the assessee's premises and that reliance was placed on evidence found at a third party's location. The Tribunal also noted the assessee's challenge to additions made beyond the six-year period and the specific grounds related to Section 68 and Section 69C. The Tribunal's decision on these grounds, including the evidentiary value of the diaries and the validity of additions, would determine the final outcome. The Tribunal decided to adjudicate the appeals based on the arguments presented and the evidence on record.

The Tribunal dismissed all appeals filed by the Revenue. For the assessee's appeals, they were partly allowed. The Tribunal found that the Revenue's grounds of appeal concerning the deletion of additions under Section 69A (Rs. 12,35,30,000/-) and Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were dismissed as discussed in previous paragraphs (para 56 and 32-55 respectively). The assessee's ground regarding the invocation of Section 115BBE was allowed based on findings in para 56. The assessee's ground regarding directions to calculate peak of unrelated transactions was allowed based on findings in para 35. The assessee's grounds concerning additions under Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were partly allowed based on findings in para 32-55. The Tribunal's reasoning for dismissing the Revenue's appeals and partly allowing the Assessee's appeals is detailed in the preceding paragraphs of the judgment, which are not fully reproduced here. The operative direction is that the Revenue's appeals are dismissed, and the Assessee's appeals are partly allowed.

The Tribunal dismissed all appeals filed by the Revenue. For the assessee's appeals, they were partly allowed. The Tribunal found that the Revenue's grounds of appeal concerning the deletion of additions under Section 69A (Rs. 12,35,30,000/-) and Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were dismissed as discussed in previous paragraphs (para 56 and 32-55 respectively). The assessee's ground regarding the invocation of Section 115BBE was allowed based on findings in para 56. The assessee's ground regarding directions to calculate peak of unrelated transactions was allowed based on findings in para 35. The assessee's grounds concerning additions under Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were partly allowed based on findings in para 32-55. The Tribunal's reasoning for dismissing the Revenue's appeals and partly allowing the Assessee's appeals is detailed in the preceding paragraphs of the judgment, which are not fully reproduced here. The operative direction is that the Revenue's appeals are dismissed, and the Assessee's appeals are partly allowed.

The Tribunal dismissed all appeals filed by the Revenue. For the assessee's appeals, they were partly allowed. The Tribunal found that the Revenue's grounds of appeal concerning the deletion of additions under Section 69A (Rs. 12,35,30,000/-) and Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were dismissed as discussed in previous paragraphs (para 56 and 32-55 respectively). The assessee's ground regarding the invocation of Section 115BBE was allowed based on findings in para 56. The assessee's ground regarding directions to calculate peak of unrelated transactions was allowed based on findings in para 35. The assessee's grounds concerning additions under Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were partly allowed based on findings in para 32-55. The Tribunal's reasoning for dismissing the Revenue's appeals and partly allowing the Assessee's appeals is detailed in the preceding paragraphs of the judgment, which are not fully reproduced here. The operative direction is that the Revenue's appeals are dismissed, and the Assessee's appeals are partly allowed.

The Tribunal held that the additions made by the Assessing Officer based on seized diaries and digital evidence were partly confirmed and partly deleted. The Tribunal also addressed grounds related to commission, unsecured loans, and unexplained expenditures.

The Tribunal dismissed all appeals filed by the Revenue. For the assessee's appeals, they were partly allowed. The Tribunal found that the Revenue's grounds of appeal concerning the deletion of additions under Section 69A (Rs. 12,35,30,000/-) and Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were dismissed as discussed in previous paragraphs (para 56 and 32-55 respectively). The assessee's ground regarding the invocation of Section 115BBE was allowed based on findings in para 56. The assessee's ground regarding directions to calculate peak of unrelated transactions was allowed based on findings in para 35. The assessee's grounds concerning additions under Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were partly allowed based on findings in para 32-55. The Tribunal's reasoning for dismissing the Revenue's appeals and partly allowing the Assessee's appeals is detailed in the preceding paragraphs of the judgment, which are not fully reproduced here. The operative direction is that the Revenue's appeals are dismissed, and the Assessee's appeals are partly allowed.

The Tribunal, following co-ordinate bench decisions, held that the compensation received for hardship and rehabilitation during redevelopment is a capital receipt and not taxable. The addition made by the AO was deleted.

The Tribunal held that the capital gain was taxable in the year under consideration as the full sale consideration was not received in the earlier year and the property was encumbered. However, it directed the AO to compute the tax on capital gains at the rate of 20% as per Section 112, even though the asset was treated as short-term under Section 50.

The Tribunal held that the appeals were liable to be dismissed in limini (at the threshold) without being admitted for hearing. The primary reasons for dismissal were two-fold: firstly, the Form 36 was not signed by a duly authorized representative of the assessee, as it was signed by Mr. Pawan Kumar Gupta, CFO, without any resolution placed on record authorizing him to file the appeal. Secondly, the assessee failed to show any sufficient cause for the condonation of the inordinate delay in filing the appeals. The reasons provided in the affidavits, such as the abrupt resignation of an unnamed accountant and the impact of COVID-19, were considered superficial, imaginary, and bereft of truth, lacking specific details like dates of resignation or names of consultants. The Tribunal found no merit in the condonation application. Consequently, both appeals were dismissed in limini as not fit for admission.

The Tribunal held that the appeals were liable to be dismissed in limini (at the threshold) without being admitted for hearing. The primary reasons for dismissal were twofold: firstly, the Form 36 was not signed by a duly authorized representative of the assessee, as no resolution was placed on record authorizing Mr. Pawan Kumar Gupta, the Chief Financial Officer, to file the appeal. Secondly, the assessee failed to demonstrate any sufficient cause for the inordinate delay in filing the appeals. The reasons provided in the affidavits, such as the resignation of an accountant and the COVID-19 pandemic, were found to be superficial, imaginary, and lacking in truth, especially considering the significant time elapsed. The Tribunal noted the absence of specific details regarding the accountant's resignation and the new consultant. Consequently, both appeals were dismissed as not fit for admission.

The Tribunal dismissed all appeals filed by the Revenue. For the assessee's appeals, they were partly allowed. The Tribunal found that the Revenue's grounds of appeal concerning the deletion of additions under Section 69A (Rs. 12,35,30,000/-) and Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were dismissed as discussed in previous paragraphs (para 56 and 32-55 respectively). The assessee's ground regarding the invocation of Section 115BBE was allowed based on findings in para 56. The assessee's ground regarding directions to calculate peak of unrelated transactions was allowed based on findings in para 35. The assessee's grounds concerning additions under Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were partly allowed based on findings in para 32-55. The Tribunal's reasoning for dismissing the Revenue's appeals and partly allowing the Assessee's appeals is detailed in the preceding paragraphs of the judgment, which are not fully reproduced here. The operative direction is that the Revenue's appeals are dismissed, and the Assessee's appeals are partly allowed.

The Tribunal dismissed all appeals filed by the Revenue. For the assessee's appeals, they were partly allowed. The Tribunal found that the Revenue's grounds of appeal concerning the deletion of additions under Section 69A (Rs. 12,35,30,000/-) and Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were dismissed as discussed in previous paragraphs (para 56 and 32-55 respectively). The assessee's ground regarding the invocation of Section 115BBE was allowed based on findings in para 56. The assessee's ground regarding directions to calculate peak of unrelated transactions was allowed based on findings in para 35. The assessee's grounds concerning additions under Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were partly allowed based on findings in para 32-55. The Tribunal's reasoning for dismissing the Revenue's appeals and partly allowing the Assessee's appeals is detailed in the preceding paragraphs of the judgment, which are not fully reproduced here. The operative direction is that the Revenue's appeals are dismissed, and the Assessee's appeals are partly allowed.

The Tribunal held that the additions made by the Assessing Officer based on seized diaries and digital evidence were partly confirmed and partly deleted. The Tribunal also addressed grounds related to commission, unsecured loans, and unexplained expenditures.

The Tribunal held that the additions made by the Assessing Officer based on seized diaries and digital evidence were partly confirmed and partly deleted. The Tribunal also addressed grounds related to commission, unsecured loans, and unexplained expenditures.

The Tribunal dismissed all appeals filed by the Revenue. For the assessee's appeals, they were partly allowed. The Tribunal found that the Revenue's grounds of appeal concerning the deletion of additions under Section 69A (Rs. 12,35,30,000/-) and Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were dismissed as discussed in previous paragraphs (para 56 and 32-55 respectively). The assessee's ground regarding the invocation of Section 115BBE was allowed based on findings in para 56. The assessee's ground regarding directions to calculate peak of unrelated transactions was allowed based on findings in para 35. The assessee's grounds concerning additions under Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were partly allowed based on findings in para 32-55. The Tribunal's reasoning for dismissing the Revenue's appeals and partly allowing the Assessee's appeals is detailed in the preceding paragraphs of the judgment, which are not fully reproduced here. The operative direction is that the Revenue's appeals are dismissed, and the Assessee's appeals are partly allowed.

The CIT(A) deleted the addition, ruling that the assessee's Section 12A registration was effectively cancelled from March 20, 2015, allowing it to be treated as an AOP and claim exemption for dividend income. The Tribunal upheld the CIT(A)'s decision, following previous coordinate bench judgments which affirmed that a trust can voluntarily opt out of 12A registration, and its cancellation is effective from the date of acquiescence to the show-cause notice.

The CIT(A) deleted the addition, ruling that the assessee's Section 12A registration was effectively cancelled from March 20, 2015, allowing it to be treated as an AOP and claim exemption for dividend income. The Tribunal upheld the CIT(A)'s decision, following previous coordinate bench judgments which affirmed that a trust can voluntarily opt out of 12A registration, and its cancellation is effective from the date of acquiescence to the show-cause notice.

The Tribunal held that the assessee should be given one more opportunity to present its case before the AO. The issues were remanded back to the AO for de novo assessment, with directions for the assessee to comply and the AO to decide on merits based on submissions and additional evidence.

The Tribunal held that the additions made by the Assessing Officer based on seized diaries and digital evidence were partly confirmed and partly deleted. The Tribunal also addressed grounds related to commission, unsecured loans, and unexplained expenditures.

The Tribunal held that the additions made by the Assessing Officer based on seized diaries and digital evidence were partly confirmed and partly deleted. The Tribunal also addressed grounds related to commission, unsecured loans, and unexplained expenditures.

The Tribunal dismissed all appeals filed by the Revenue. For the assessee's appeals, they were partly allowed. The Tribunal found that the Revenue's grounds of appeal concerning the deletion of additions under Section 69A (Rs. 12,35,30,000/-) and Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were dismissed as discussed in previous paragraphs (para 56 and 32-55 respectively). The assessee's ground regarding the invocation of Section 115BBE was allowed based on findings in para 56. The assessee's ground regarding directions to calculate peak of unrelated transactions was allowed based on findings in para 35. The assessee's grounds concerning additions under Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were partly allowed based on findings in para 32-55. The Tribunal's reasoning for dismissing the Revenue's appeals and partly allowing the Assessee's appeals is detailed in the preceding paragraphs of the judgment, which are not fully reproduced here. The operative direction is that the Revenue's appeals are dismissed, and the Assessee's appeals are partly allowed.

The Tribunal dismissed all appeals filed by the Revenue. For the assessee's appeals, they were partly allowed. The Tribunal found that the Revenue's grounds of appeal concerning the deletion of additions under Section 69A (Rs. 12,35,30,000/-) and Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were dismissed as discussed in previous paragraphs (para 56 and 32-55 respectively). The assessee's ground regarding the invocation of Section 115BBE was allowed based on findings in para 56. The assessee's ground regarding directions to calculate peak of unrelated transactions was allowed based on findings in para 35. The assessee's grounds concerning additions under Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were partly allowed based on findings in para 32-55. The Tribunal's reasoning for dismissing the Revenue's appeals and partly allowing the Assessee's appeals is detailed in the preceding paragraphs of the judgment, which are not fully reproduced here. The operative direction is that the Revenue's appeals are dismissed, and the Assessee's appeals are partly allowed.

The Tribunal dismissed all appeals filed by the Revenue. For the assessee's appeals, they were partly allowed. The Tribunal found that the Revenue's grounds of appeal concerning the deletion of additions under Section 69A (Rs. 12,35,30,000/-) and Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were dismissed as discussed in previous paragraphs (para 56 and 32-55 respectively). The assessee's ground regarding the invocation of Section 115BBE was allowed based on findings in para 56. The assessee's ground regarding directions to calculate peak of unrelated transactions was allowed based on findings in para 35. The assessee's grounds concerning additions under Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were partly allowed based on findings in para 32-55. The Tribunal's reasoning for dismissing the Revenue's appeals and partly allowing the Assessee's appeals is detailed in the preceding paragraphs of the judgment, which are not fully reproduced here. The operative direction is that the Revenue's appeals are dismissed, and the Assessee's appeals are partly allowed.

The Tribunal dismissed all appeals filed by the Revenue. For the assessee's appeals, they were partly allowed. The Tribunal found that the Revenue's grounds of appeal concerning the deletion of additions under Section 69A (Rs. 12,35,30,000/-) and Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were dismissed as discussed in previous paragraphs (para 56 and 32-55 respectively). The assessee's ground regarding the invocation of Section 115BBE was allowed based on findings in para 56. The assessee's ground regarding directions to calculate peak of unrelated transactions was allowed based on findings in para 35. The assessee's grounds concerning additions under Section 69C (Rs. 1,05,00,000/- and Rs. 6,54,000/-) were partly allowed based on findings in para 32-55. The Tribunal's reasoning for dismissing the Revenue's appeals and partly allowing the Assessee's appeals is detailed in the preceding paragraphs of the judgment, which are not fully reproduced here. The operative direction is that the Revenue's appeals are dismissed, and the Assessee's appeals are partly allowed.

The Tribunal held that the AO should consider only those investments that yield exempt income when computing disallowance under Section 14A read with Rule 8D, following a Special Bench decision.