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Bank Deposits of Business Correspondent Handling Customer Funds Require Verification — ITAT Allahabad Sets Aside Addition u/s 69 & 115BBE in Suraj Kumar Tiwari vs. ITO Ward-1(5), Bhadohi (ITA No.35/ALLD/2024, AY 2017-18)
Facts of the CaseThe assessee filed his return declaring income of ₹2,10,140
under the head “Income from Other Sources.” He was working as a Business
Correspondent (BC) for the State Bank of India, Gopiganj Branc...
Entire Bank Deposits Cannot Be Taxed as Unexplained When Linked to Business Receipts — ITAT Allahabad Orders De Novo Assessment in Suneel Kumar Gupta vs. ITO Ward-2(2)(5), Banda (ITA No.46/ALLD/2024, AY 2017-18)
Facts of the CaseThe Assessing Officer received information that the assessee
had deposited ₹17,86,000 during the demonetization period in his State Bank of
India account. Multiple notices under section 142(1) were i...
Bank Deposits of Employer’s Business Receipts Cannot Be Taxed as Employee’s Income Without Proper Enquiry — ITAT Allahabad Remands Section 69A Addition in Shyamlo Datt Shukla vs. ITO Ward-2(3), Allahabad (ITA No.29/ALLD/2024, AY 2012-13)
Facts of the CaseBased on AIR information indicating cash deposits of
₹45,16,000 in the assessee’s savings bank account, reassessment proceedings
were initiated under section 147 by issuing notice under section 148...
NFAC Cannot Dismiss Appeals Ex-Parte Without Deciding Capital Gains Issues — ITAT Allahabad Restores LTCG Dispute on Property Sale in Abhay Narayan Pandey vs. ACIT Circle-1(1), Allahabad (ITA Nos.42 & 43/ALLD/2024, AYs 2012-13 & 2017-18)
Facts of the CaseFor AY 2012-13, the assessee originally filed a return
declaring income of ₹16,00,650. Information was later received regarding sale
of property at Greater Noida for ₹7,40,47,000. Reassessment proc...
Ex-Parte Reassessment with Multiple Additions on Property Purchase Set Aside — ITAT Allahabad Grants Fresh Opportunity in Shakeel Hussain vs. ACIT (NFAC), Delhi (ITA No.31/ALLD/2024, AY 2015-16)
Facts of the CaseThe assessee filed his return declaring income of ₹10,48,170.
The Assessing Officer received information that the assessee had jointly
purchased immovable property at Tignauta, Naini, Allahabad with ...
Section 115BBE Cannot Apply to Surplus of Educational Fees — ITAT Allahabad Allows Rectification u/s 154 in Saraswati Vidhya Mandir Inter College vs. ITO Ward-2(2)(5), Banda (ITA No.69/ALLD/2024, AY 2017-18)
Facts of the CaseThe assessee, an educational institution, had not filed its
return of income. Information was received regarding cash deposits during the
demonetization period. Notices under section 142(1) were issued...
Ex-Parte Reassessment for Bank Deposits Set Aside — ITAT Allahabad Grants Fresh Opportunity in Santosh Kumari Sahu vs. ITO (NFAC), Delhi (ITA No.44/ALLD/2024, AY 2017-18)
Facts of the CaseThe Assessing Officer received information regarding financial
transactions in the assessee’s bank accounts maintained with State Bank of
India and Bank of Baroda. Since the assessee had not filed a ...
Demonetization Deposits & Bank Credits Cannot Be Added Without Verifying Portal Submissions — ITAT Allahabad Remands Case Where “Cash Transaction-2016” Compliance Ignored in Sachidanand Rai vs. ITO 1(4), Bhadohi (ITA No.11/ALLD/2024, AY 2017-18)
Facts of the CaseThe assessee deposited ₹12,46,000 during the demonetization
period in his Canara Bank account. Despite issuance of multiple notices, he did
not respond during assessment proceedings. Consequently, th...
Wrong Reporting in Tax Audit Report Causing Double Taxation u/s 143(1) Requires Fresh Verification — ITAT Allahabad Remands CPC Adjustment Case in S.P.S. Automobiles vs. ITO Ward-1(5), Prayagraj (ITA No.106/Alld/2024, AY 2021-22)
Facts of the CaseThe assessee, a partnership firm engaged in automobile
dealership (purchase and sale of tractors), filed its return along with audited
financial statements and tax audit report declaring income of ₹3...
High-Pitched Ex-Parte Assessment u/s 144 for Demonetization Cash Deposits Set Aside — ITAT Allahabad Grants Fresh Opportunity in Ramesh Stone Crusher Co. vs. ACIT-3, Mirzapur (ITA No.38/ALLD/2024, AY 2017-18)
Facts of the CaseThe assessee-firm filed its return declaring income of
₹28,59,260. The case was selected for scrutiny, and multiple notices under
sections 143(2) and 142(1) were issued. Due to non-compliance, the As...