The Tribunal held that deduction claims should not be rejected for technical non-compliance. It emphasized that substantive provisions prevail over procedural requirements.
The new ECB framework removes rigid conditions and introduces flexibility in borrowing and repayment. It significantly improves ease of access to global funding.
ITAT held that interest earned on bank deposits is taxable and not covered by the principle of mutuality. The ruling confirms that dealings with third parties break mutuality protection.
The Tribunal admitted a new legal ground and held that jurisdictional defects can be raised at any stage. It quashed the assessment as the initial notice itself was issued without authority.
ITAT held reassessment invalid as it was based on already examined facts without fresh material. The ruling reinforces that reopening on mere change of opinion is not permissible.
ITAT held that section 249(4) cannot be invoked where no taxable income arises in India. Appeals must be decided on merits rather than dismissed on technical grounds.
The Tribunal ruled that even temporary withdrawals by a shareholder can trigger deemed dividend under Section 2(22)(e). It held that duration or repayment does not negate taxability.
The ruling clarifies that unauthenticated digital chats and screenshots cannot form the sole basis of tax additions without proper verification and legal compliance.
The court held reassessment invalid where proceedings were based solely on unverified digital material from unrelated parties. It ruled that absence of a live nexus with income escapement makes reopening unsustainable.
The Tribunal ruled that failure to obtain prior approval for loans is only a procedural lapse. It directed reconsideration of 12A registration after acknowledging genuine charitable activities.
