The Supreme Court held that a collaborator essential to contract execution and bound through a Deed of Joint Undertaking can invoke the arbitration clause despite not being a direct signatory.
The Pune ITAT held that entire cash deposits in bank accounts cannot automatically be treated as unexplained income when the assessee appears to be only a conduit in an accommodation entry network. The Tribunal restricted the taxable addition to 2% of deposits after finding no evidence of actual enrichment.
Pune ITAT held that accounting reclassification entries and journal adjustments require proper verification before being treated as unexplained income. The matter was remanded after admitting additional evidence.
Pune ITAT held that penalty for under-reporting of income cannot survive where the Assessing Officer accepts the income declared in response to notice under Section 148 without any addition. The Tribunal deleted the entire penalty under Section 270A.
Pune ITAT held that appellate authorities must adjudicate issues raised in appeals and cannot mechanically dismiss matters for non-compliance. The Tribunal restored the case for fresh consideration on merits.
Pune ITAT observed that reassessment proceedings initiated beyond three years may not be maintainable where the alleged escaped income is below ₹50 lakh. The matter was remanded for verification of jurisdictional facts and statutory notices.
The ITAT ruled that generation of surplus and project-based contractual arrangements do not automatically convert environmental conservation activities into commercial ventures. The Tribunal directed grant of Section 12A registration after finding the activities genuinely charitable.
The ITAT observed that interest awarded under Section 28 of the Land Acquisition Act differs from ordinary interest under Section 34 and forms part of enhanced compensation. Therefore, taxation provisions relating to interest income were held inapplicable.
Mumbai ITAT upheld ₹10.76 crore addition after rejecting selective identification of physical shares for capital gains computation. The Tribunal termed the arrangement a “colourable device” to suppress taxable gains.
The Tribunal held that the charitable trust mistakenly filed Form 10AB under an incorrect clause of Section 12A due to a bona fide error. ITAT directed the CIT(E) to permit correction of the application and reconsider registration on merits.
