The issue was whether delayed filing of return bars deduction under Section 10AA. ITAT held that timely filing was not mandatory for the relevant years and allowed the deduction.
The tribunal examined whether delayed filing of Form 67 bars foreign tax credit. It held that filing before completion of assessment is sufficient, allowing the credit.
Smt. Satyabhama Vs DCIT (ITAT Hyderabad) The Hyderabad ITAT deleted the addition of ₹16.55 lakh u/s 69A, holding that cash found during search was duly explained by earlier accepted cash balance. The Tribunal also condoned a 97-day delay, adopting a liberal approach considering the assessee’s age, lack of digital access, and procedural difficulties. On merits, […]
The issue was whether third-party diaries using code “DD” can justify 153C action. ITAT held that without clear identification and corroboration, such evidence is insufficient and proceedings are invalid.
The Tribunal held that complete disallowance was excessive despite lack of full documentation. It allowed 50% deduction considering business necessity. Key takeaway: partial evidence can justify partial allowance.
The Tribunal held that cash disclosed in earlier returns can explain seized cash. It restricted addition to the unexplained portion. Key takeaway: prior disclosures carry strong evidentiary value.
The Tribunal invalidated reopening as the AO obtained approval from the wrong authority. It held that compliance with Section 151 is a jurisdictional requirement. Key takeaway: improper sanction nullifies reassessment.
The issue was whether stamp duty value of redevelopment property is taxable without possession. ITAT held that Section 56(2)(x) applies only on actual receipt, so no tax arises without possession.
The issue was whether delay in filing appeal can be condoned when assessment order was not served. ITAT held that non-service constitutes sufficient cause, requiring fresh adjudication on merits.
The issue was addition of cash found during search claimed to belong to the assessee’s mother. The Tribunal allowed partial relief, accepting some explanations based on evidence and probabilities while sustaining the balance.
