The Tribunal held that rejection of the appeal without a reasoned order violated appellate duties. All issues were restored for de novo consideration with directions to ensure due opportunity.
Authorities taxed refund interest as business income by linking it to earlier PE years. The Tribunal ruled that without a PE in the year of receipt, the income cannot be treated as effectively connected and must enjoy DTAA relief.
The Tribunal emphasized that exemption cannot be denied on assumptions. It restored the case to the AO for limited verification, reinforcing evidence-based assessment by the Income Tax Appellate Tribunal.
The issue was whether cash deposited during demonetisation could be taxed as unexplained money. The Tribunal held that prior withdrawals from the bank sufficiently explained the deposits, warranting deletion of the addition.
The tribunal refused to admit a fresh legal challenge to reassessment raised for the first time. However, it remanded the revenue-difference addition for fresh adjudication due to natural justice concerns.
The case addressed whether an authority can reject registration before completion of parallel statutory processes. The Tribunal held that hurried rejection was unjustified and directed de novo adjudication.
The Finance Bill, 2026 clarifies that section 144C timelines govern final assessment orders. Sections 153 and 153B apply only up to the draft order stage, ending years of controversy.
The amendment clarifies how the sixty-day period under transfer pricing law must be calculated. It removes ambiguity that had led to annulment of assessments despite timely action by the TPO.
Payments made pursuant to allotment confer valuable property rights. Their relinquishment through an agreement to sell amounts to a statutory transfer, entitling the assessee to compute gains or losses under capital gains.
The amendments modify shipping tax provisions to fully integrate inland vessels into the tonnage tax regime. Regulatory references, certification norms, and compliance requirements are aligned with inland waterways law.
