ITAT ruled that an allotment letter constitutes a valid agreement for section 56(2)(x) where consideration and binding terms are recorded. Stamp duty value on the allotment date, not the delayed registration date, must be applied.
ITAT remanded a ₹2.90 crore s.54F deduction case, allowing the assessee to furnish complete documentation and have the claim re-examined on merit.
ITAT acknowledged that ECB interest was fixed and consistently accepted in earlier years but adopted a marginally revised rate after the assessee’s voluntary settlement to close the dispute.
The Tribunal ruled that section 263 cannot be invoked merely because no addition was made during reassessment. When the AO conducts proper enquiries and accepts the explanation, revision fails for lack of error and prejudice.
The Registrar held that not serving annual reports within the prescribed time violates statutory disclosure obligations. Informal or oral practices cannot replace mandatory compliance.
The Tribunal rejected the Revenue’s claim that breed development expenses are capital merely due to long-term benefits. What matters is business purpose and operational nexus, not incidental endurance.
The issue concerned excess interest deduction claimed by inflating EBITDA through Ind-AS fair-value adjustments. ITAT held that the AO made no enquiry on this critical computation, making the assessment erroneous.
The issue was whether a later retraction could override an admission made during search proceedings. ITAT held that a clear statement under section 132(4) has high evidentiary value and cannot be nullified without strong proof.
The Tribunal ruled that a statutory appellate authority cannot pass an ex-parte order after ignoring materials demonstrably available on record. The matter was restored for fresh consideration on all grounds.
The Tribunal reaffirmed that revision is impermissible when the Assessing Officer adopts a reasonable view after due enquiry. Section 263 cannot be invoked merely because the PCIT prefers another line of investigation.
