ITAT held that Section 50C proviso is retrospective, allowing stamp duty value as on the agreement date where consideration was fixed earlier, significantly reducing LTCG exposure.
The tribunal held that mere absence of substantial activities since inception is not conclusive where charitable objects are genuine. A fresh opportunity must be granted to substantiate activities with evidence.
The tribunal held that reassessment beyond three years is invalid when alleged escaped income is below Rs. 50 lakh. Notices issued contrary to section 149 after the 2021 amendments were quashed for lack of jurisdiction.
The tribunal held that invoking Section 115BBE on survey-related excess stock was legally unsustainable for AY 2015-16. The addition was therefore liable to be taxed at normal rates.
The ITAT held that late filing of Form 67 cannot defeat a valid FTC claim. The ruling clarifies that procedural delays do not override substantive treaty rights.
The tribunal held that non-filing of return within the due date disentitled the assessee from deduction under section 80P due to section 80AC. Consequently, lower profit claims based on accounts were rejected.
The tribunal observed that Way Bills produced by the assessee prima facie supported the claim of business sales. The addition was therefore set aside and restored for fresh verification.
The tribunal deleted the balance addition of ₹91,090 after finding that the amounts represented periodic rental receipts duly disclosed with TDS credit. The key takeaway is that disclosed income cannot be re-taxed as unexplained cash.
The issue was the validity of a penalty notice combining concealment and furnishing inaccurate particulars. The ITAT ruled that vague notices violate natural justice and quashed the penalty.
The ITAT set aside a ₹1.86 crore addition under section 69A for unexplained deposits, noting the deposits were likely student fees. The ruling emphasizes the need to verify exempt income before making tax additions.
