ITAT Pune rules that delay in filing Form 67 is a procedural lapse and cannot deny Foreign Tax Credit under Section 90; directs AO to grant ₹2.74 lakh FTC after verification, upholding substantive relief despite delay.
ITAT Mumbai deletes ₹27.40 lakh addition under Section 69A, holding cash deposits as genuine business advances for car bookings, duly supported by confirmations, PAN, and invoices; non-response of customers cannot justify addition without proper verification.
The ruling clarified that unverified electronic records and third-party statements cannot justify additions without proper verification. The absence of direct linkage and corroboration led to deletion of additions.
ITAT Hyderabad quashes reassessment as Section 148 notice, though dated 31.03.2021, was actually issued on 01.04.2021; failure to follow mandatory Section 148A procedure and obtain proper approval rendered proceedings invalid.
ITAT Pune sets aside ₹11.57 lakh disallowance under Section 36(1)(va) for alleged PF/ESI delay, citing conflicting Supreme Court views in Woodland vs Checkmate; matter remanded to CIT(A) for fresh factual and legal adjudication.
ITAT Hyderabad deletes Section 69A additions in alleged penny stock case, holding that documented share transactions cannot be treated as bogus based on suspicion or general investigation reports without specific evidence against the assessee.
ITAT Mumbai rules scholarships to Indian students studying abroad qualify as valid charitable application in India. Denial of 12AB and 80G set aside, clarifying registration stage scope is limited to objects and genuineness.
ITAT Mumbai quashes ₹1.64 Cr reassessment for faceless violation & time-barred notice u/s 148; holds jurisdictional defect fatal, TOLA cannot extend limitation.
The Tribunal examined whether reassessment notices issued by a jurisdictional officer instead of a faceless authority were valid. It held such notices invalid, quashing the entire reassessment proceedings.
The Tribunal held reassessment invalid as the alleged escaped income did not exceed ₹50 lakh required for extended limitation. It ruled that invoking extended time under Section 149 without satisfying this condition is illegal.
