The tribunal held that indexed cost of acquisition must be allowed while computing LTCG of a charitable trust. Indexation under Section 48 applies even when gains are treated as application of income under Section 11(1A).
The tribunal deleted penalty where the quantum addition was restricted to an estimated profit element. It held that penalty cannot survive without a clear finding of concealment.
Explains the CBDT notification granting section 10(46) exemption to a district legal services authority and the categories of income covered.
The Court held that delay in filing Form 10-IC could not be rejected where the return form itself lacked a functional option field. Substantive compliance with Section 115BAA was found sufficient to grant the concessional tax rate.
The Court held that once late fees are imposed for delayed filing of returns under Section 47, a general penalty under Section 125 cannot be added. The ruling clarifies the mutually exclusive application of these penalty provisions.
The Tribunal affirmed restricting Section 14A disallowance to the actual exempt income earned. It also held the Finance Act, 2022 explanation to be prospective, protecting taxpayers for earlier years.
Officers say compressed timelines are being enforced despite persistent ITBA issues and staff shortages. The key takeaway is a call for realistic deadlines or statutory extensions to protect assessment quality.
The dispute involved additions made despite small variations between agreement value and stamp duty value. The Tribunal ruled that differences within 10% are immune from Section 43CA, granting relief for genuine transactions.
The ruling clarifies that CSR-related disallowance under Section 37(1) applies only from AY 2015-16 onwards. For earlier years, expenses with a business nexus remain deductible.
The Budget introduces extended timelines, updated-return flexibility, and fewer prosecutions. The key takeaway is a shift from punishment to voluntary compliance.
