Condonation of 100 + month delay allowed on liberal principles with ₹5,000 cost; ITAT holds gross receipts of charitable trust cannot be taxed-even if Sec 11 denied, only net income after expenses is taxable; matter remanded for verification.
TP ruling clarifies that comparables must meet uniform filters, FAR analysis prevails over search matrix, ESOP adjustments require parity, working capital needs scientific computation, and delayed receivables attract LIBOR-based interest.
The Tribunal held that unsigned sanction for reopening invalidates the entire reassessment. It ruled that absence of signature violates mandatory legal requirements under tax law.
The relocation did not lead to structural enhancement of business assets. The Tribunal ruled that such expenses remain in the revenue field. The decision distinguishes between operational and capital expenditure.
The Tribunal accepted the delay caused by representative’s illness as sufficient reason and admitted the appeal. It found that the authority failed to properly assess genuineness of activities. The matter was restored for fresh adjudication.
The Tribunal relied on Supreme Court precedent to hold that interest on tax arrears is compensatory, not penal. It ruled that such interest qualifies as a deductible business expense.
The Tribunal held that excess stock found during survey had direct nexus with business operations. It ruled that such income should be taxed as business income, not as unexplained investment under special provisions.
The Tribunal held that absence of a clear charge in the penalty notice makes the proceedings invalid. It ruled that failure to specify the exact limb of misreporting renders the penalty unsustainable.
The Tribunal held that prior to the 2023 amendment, returns filed within the broader time under Section 139 were eligible for exemption. It ruled that updated returns could not be denied benefits retrospectively.
The issue involved dismissal of appeal due to delay and non-appearance. The tribunal condoned the delay citing medical reasons and remanded the matter for fresh assessment, imposing cost for non-compliance.
