he Tribunal observed that confirmation of additions without examining affidavits and tax returns of close relatives is legally flawed. The matter was remanded for fresh adjudication.
The Tribunal held that assignment of a life interest under a trust does not amount to transfer of land or building. Since only a limited, determinable right was transferred, Section 50C could not be invoked.
The Tribunal held that a summary and presumptive approval under Section 153D vitiates the entire assessment. Lack of independent application of mind by the approving authority renders the assessment non-est.
The Tribunal observed that the purpose of revision is to protect revenue interests. When no tax demand arises in consequential proceedings, the revision order no longer calls for adjudication.
The Tribunal ruled that where more than three years have elapsed, sanction must come from the Principal Chief Commissioner. Approval by the Principal Commissioner renders the reassessment void ab initio.
The Tribunal set aside the appellate order after finding that no enquiry was conducted despite clear evidence in Form 26AS. The ruling underscores that undisputed pension income cannot be ignored without verification.
The Tribunal held that eligibility of deduction on interest from scheduled banks depends on whether funds are operational to the credit business. The matter was remanded to verify the society’s activities and source of funds.
The Tribunal dismissed the appeals as time-barred since no application for condonation of delay was filed despite repeated opportunities. In the absence of any explanation, the appeals were held not maintainable.
The Tribunal held that a notice issued under section 148 on 31.07.2022 for AY 2014-15 was barred by limitation under the amended section 149. Reassessment proceedings were quashed as void ab initio.
The Delhi High Court held that sponsorship payments included consideration for worldwide use of event trademarks. The ruling confirms that such rights constitute royalty liable to withholding tax.
