The Tribunal held that the 2022 amendment cannot shorten the utilization period for past accumulations. Only the unspent Rs.90,000 was taxable, not the entire Rs.6,75,000.
The Tribunal restricted on-money profits to 15%, deleted Transfer Pricing additions, and confirmed bogus purchase disallowances. Jurisdictional objections based on CBDT pecuniary instructions were rejected. The case provides guidance on treatment of search-assessment adjustments and substantiation requirements.
ITAT held that additions based on an unsigned, unverified Excel sheet from a third party lacked evidentiary value. The reassessment was quashed as the assessee provided independent evidence disproving alleged on-money payments.
ITAT held that a trust’s application for 80G approval cannot be rejected solely for having religious objects in its deed. The matter was remanded for fresh verification of actual religious expenditure.
ITAT remanded the unexplained cash credit addition for verification of full loan repayment, highlighting that repayment within a reasonable time negates the addition under section 68.
The Tribunal allowed the assessee’s claim under Section 44AD, recognizing the small kirana shop’s sales and deposits as genuine business income. Bank deposits corresponded with daily sales, and withdrawals matched purchase requirements, showing a consistent business pattern.
ITAT held that discretionary trusts with unknown beneficiary shares must be taxed at the maximum marginal rate unless statutory exceptions apply, restoring the matter for verification.
The High Court held that forklifts and cranes with on/off-road capability fall within Section 2(28) and require compliance with registration and tax provisions. Machinery designed for off-highway use but capable of road travel cannot claim exemption.
The Tribunal held the reassessment invalid since notices and the final order were issued in the name of a dead assessee despite the Department being informed. Key takeaway: assessments against deceased persons are void ab initio.
The Tribunal ruled that the AO’s imposition of ₹30,000 was contrary to Section 272A(1)(d), which permits only ₹10,000 per statutory default. As only one true default existed, the excess penalty was deleted. Key takeaway: penalty must be grounded strictly in statutory authority, not administrative repetition.
