The Tribunal held that Section 69A applies only to money not recorded in books of account. Additions based on duly recorded, bank-routed transactions were found unsustainable.
ITAT Delhi directed that a trust lacking 12A registration cannot be taxed on gross receipts; only surplus income applied outside charitable purposes is taxable.
LL Global Inc. Vs ACIT (ITAT Delhi) ₹50 Lakh Threshold Is Mandatory: ITAT Delhi Quashes Reassessment of Foreign Company as Time-Barred Delhi ITAT (Bench ‘D’) quashed the reassessment proceedings initiated u/s 147 r.w.s. 148, holding them to be barred by limitation under the amended law. The Tribunal noted that the notices u/s 148 were issued […]
ITAT Delhi ruled that CIT(E) cannot evaluate the merit of charitable activities when granting 12AB/80G registration, restoring the trust’s exemptions. Procedural overreach by tax authorities cannot deny valid registration.
ITAT Delhi ruled that a sub-broker’s turnover includes only brokerage income, not total client transactions, and deleted ₹1.5 lakh penalty under Section 271B.
ITAT allowed condonation of a 321-day delay in appeal filing, emphasizing procedural fairness when assessment orders are delivered electronically.
The Tribunal held that while section 14A applies to partnership investments, disallowance cannot exceed the amount excluded from total income. Excess Rule 8D disallowance was therefore restricted to the partnership loss.
