The issue was whether third-party diaries and loose papers could establish receipt of unaccounted income. The Tribunal ruled that such papers, without authorship verification or corroboration, cannot fasten tax liability.
This ruling clarifies that an assessee can be treated as an agent of a non-resident only if income is received directly or indirectly for the NRI. In the absence of such receipt or business connection, representative assessment fails.
The issue was whether the NCLT could declare ownership of a trademark during CIRP. The Supreme Court held that title disputes not arising directly from insolvency fall outside Section 60(5) jurisdiction.
The Tribunal held that while fee suppression was established during survey proceedings, the entire difference could not be taxed. Only the gross profit on suppressed receipts, excluding GST, is chargeable to tax.
The decision reiterates that when books of account, sales, and inventory are accepted, purchase disallowances cannot be made mechanically. Suspicion cannot replace proof in tax proceedings.
The Tribunal ruled that completion of assessment after search, despite statutory abatement, is impermissible. Jurisdiction shifts exclusively to Section 153A proceedings.
The issue was whether utilisation of corpus donations for expenditure converts them into taxable income. The Tribunal held that corpus retains its exempt character when used as per donor directions and trust deed.
The issue was whether reassessment after three years was barred by limitation. The Tribunal held it valid since the escaped income exceeded ₹50 lakh, attracting the extended reopening window.
The tribunal held that penalty under Section 270A cannot be levied where the assessee voluntarily withdrew the education cess claim after a retrospective amendment. A bona fide claim made on prevailing judicial views does not amount to under-reporting or misreporting.
The case examined penalty levied on estimated additions and statutory disallowance. The Tribunal held that neither category amounts to concealment or inaccurate particulars.
