The Tribunal held that additional evidence accepted by the appellate authority must be examined by the Assessing Officer. Allowance based only on banking payments and charitable status was found inadequate.
Emphasising substance over form, the ruling clarifies that genuine charitable trusts should not be denied renewal solely on procedural timelines where reasonable cause exists.
The Tribunal held that additions for completed assessment years under section 153A are invalid when no incriminating material is found during search. Reliance on third-party documents and uncorroborated statements was held insufficient to sustain additions.
The Tribunal ruled that the six-month time limit from commencement of activities applies only to newly formed trusts. Long-standing trusts cannot be denied approval solely on this ground.
The ruling clarifies that the power to admit or reject appeals under section 249(4) lies with NFAC/RFAC, not the Appeal Unit. Appeals were restored due to improper exercise of jurisdiction.
The Tribunal held that when corresponding sales are accepted, a full disallowance of alleged bogus purchases is not justified. It restricted the addition to 6% of the purchase value as a reasonable estimate.
The AO accepted documents but still made an addition without pointing out defects. The Tribunal ruled that section 68 requires adverse findings, not assumptions.
The Tribunal examined whether delayed filing of Form 67 can defeat a valid FTC claim. It ruled that Rule 128(9) is directory and FTC cannot be denied when substantive conditions are met.
The CPC taxed interest solely based on Form 26AS despite the assessee following the cash method. The Tribunal ruled that taxation requires verification of receipt and remanded the issue to the AO.
The issue was whether a reassessment notice for AY 2015–16 issued after 31 March 2022 was valid. The Tribunal held the notice time-barred and quashed the entire reassessment proceedings.
