HON'BLE MR. JUSTICE J.K. MAHESHWARI HON'BLE MR. JUSTICE ATUL S. CHANDURKAR

HON'BLE MR. JUSTICE SANJAY KAROL HON'BLE MR. JUSTICE AUGUSTINE GEORGE MASIH

HON'BLE MR. JUSTICE AHSANUDDIN AMANULLAH HON'BLE MR. JUSTICE R. MAHADEVAN

HON'BLE MR. JUSTICE VIKRAM NATH HON'BLE MR. JUSTICE SANDEEP MEHTA

HON'BLE MR. JUSTICE PANKAJ MITHAL HON'BLE MR. JUSTICE S.V.N. BHATTI

HON'BLE MR. JUSTICE PRASHANT KUMAR MISHRA HON'BLE MR. JUSTICE N.V. ANJARIA

SHRI TR SENTHIL KUMAR (Judicial Member), SHRI NARENDRA PRASAD SINHA (Accountant Member)

The ITAT partly allowed the appeal, upholding an addition of Rs. 14,02,500/- for unexplained cash deposits while granting relief for Rs. 10,00,000/-. It also ruled that the amended Section 115BBE, effective from 15.12.2016, could not be applied to cash deposits made prior to that date.

SHRI PAVAN KUMAR GADALE (Judicial Member)

The Tribunal held that interest income earned by a cooperative society from its deposits with other cooperative banks is eligible for deduction under Section 80P(2)(d) of the Act. For interest income from scheduled banks, the issue was restored to the AO for adjudication based on specific directions.

DR. ARJUN LAL SAINI (Accountant Member), DR. DINESH MOHAN SINHA (Judicial Member)

The Tribunal noted that the Assessing Officer had travelled beyond the scope of limited scrutiny, which was the basis for the assessment. The Tribunal followed its earlier decision in the assessee's brother's case, which dealt with identical facts and issues. Consequently, the disallowance and addition made by the Assessing Officer and sustained by the CIT(A) were deleted.

DR. ARJUN LAL SAINI (Accountant Member), DR. DINESH MOHAN SINHA (Judicial Member)

The Tribunal condoned the delay, finding a "sufficient cause" for the late filing. Upon examining the facts, the Tribunal noted that while the AO and CIT(A) confirmed the addition, the assessee claimed compliance with Section 68 and relied on a Gujarat High Court judgment. The Tribunal decided to provide the assessee an opportunity to further establish the genuineness of the transaction before the AO.

DR. ARJUN LAL SAINI (Accountant Member), DR. DINESH MOHAN SINHA (Judicial Member)

The Tribunal held that the grounds challenging the validity of notice issued under Section 147/148 of the Income Tax Act were dismissed in light of previous decisions in the assessee's own group cases. Regarding the profit estimation on 'on-money', the Tribunal found the higher estimations by the lower authorities to be excessive and, following jurisdictional High Court judgments, directed that the profit element on 'on-money' should be estimated at a uniform rate of 10%. The revenue's appeals were dismissed, and the assessee's appeals were partly allowed.