Tribunal held that delays caused by pandemic disruptions and internal management-auditor communication issues constitute reasonable cause under Section 274, deleting ₹2.42 lakh penalty.
The addition was based on a loose paper that did not match Yes Bank loan details or HMA ledger figures. The Tribunal upheld that such uncorroborated papers cannot sustain a 69C addition, especially when business had not yet commenced. The takeaway is that tax additions must be backed by verifiable evidence, not estimations on loose sheets.
ITAT Agra held that purchases made by a tenant cannot be attributed to the landlord, deleting ₹2.50 crore addition for alleged bogus meat purchases, emphasizing factual accuracy in assessments.
The Tribunal held that even extraordinary circumstances like COVID-19 do not justify appeals filed after limitation expiry. The assessee’s appeal was dismissed due to failure to provide cogent reasons or affidavits supporting the delay.
ITAT Pune ruled that income from temporarily letting sugar factory assets is business income, not Income from Other Sources, allowing set-off of brought-forward losses.
Delhi ITAT held that adding hypothetical interest on security deposits to compute ALV is impermissible. The decision reverses lower authorities, confirming that only real contractual rent counts as income under section 23(1).
Delhi High Court held that completed assessments cannot be disturbed without any incriminating material found during search. The Court dismissed Revenue’s appeal, reaffirming that additions under section 153A require evidence of undisclosed income or assets.
The Court ruled that services rendered remotely cannot create a PE because the treaty requires services furnished within India through employees. virtual presence cannot substitute physical presence without treaty amendment.
The Supreme Court rejected the High Courts view that nomination alone guarantees absolute entitlement. It emphasized that beneficiaries must follow succession law, splitting the GPF 50% each between eligible family members.
The Court held that both salary and farm income must be considered, increasing the deceased’s monthly income to ₹8,000. ignoring legitimate income sources leads to undervalued compensation.
