Since the reassessment itself was quashed, the addition treating long-term capital gains as unexplained cash credit under section 68 automatically failed. Jurisdictional defects were fatal to the assessment.
The Tribunal ruled that maintaining a temple or holding festivals does not disqualify a trust if substantial funds are spent on public welfare. Authorities must examine actual expenditure patterns, not assumptions.
ITAT Cuttack held that reassessment proceedings fail when no addition is made on the very reasons recorded for reopening. If the original ground disappears, the entire reassessment becomes invalid.
The Tribunal ruled that the PCIT lacked jurisdiction to revise an assessment when the very issue was already under challenge before the appellate authority. Parallel revision proceedings were held to be impermissible.
Additions based on survey-time valuation of machinery were deleted as the Assessing Officer had not rejected the books of account. Prior binding orders in the same case were followed, reaffirming settled law.
The Tribunal ruled that interest earned on Government grants parked under official directions cannot be divorced from the original grant. Denial of exemption was found to defeat the purpose of section 10(23C)(iiiab), leading to relief for the assessee.
The issue was whether late filing of Form 10AB mandates rejection of registration. The Tribunal held that bona fide delay can be condoned and remanded the matter for fresh consideration.
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.
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.
