The issue was denial of FTC due to delayed filing of Form 67. ITAT held that delay is procedural and directed authorities to grant credit after verification.
The issue was whether penalty under Section 270A is valid without specifying the exact charge. ITAT held that absence of a specific limb of misreporting makes the penalty invalid.
The issue was denial of registration due to non-commencement of activities. ITAT held that proposed activities and initial steps like investment are sufficient and ordered reconsideration.
The issue was whether jewellery found during search can be taxed despite CBDT limits. ITAT held that jewellery within prescribed limits cannot be treated as unexplained income.
The issue was denial of deduction due to delayed filing of Form 56F. ITAT held that delay is a procedural lapse and directed allowance of deduction.
The issue was whether delayed filing of return bars deduction under Section 10AA. ITAT held that timely filing was not mandatory for the relevant years and allowed the deduction.
The tribunal examined whether delayed filing of Form 67 bars foreign tax credit. It held that filing before completion of assessment is sufficient, allowing the credit.
Smt. Satyabhama Vs DCIT (ITAT Hyderabad) The Hyderabad ITAT deleted the addition of ₹16.55 lakh u/s 69A, holding that cash found during search was duly explained by earlier accepted cash balance. The Tribunal also condoned a 97-day delay, adopting a liberal approach considering the assessee’s age, lack of digital access, and procedural difficulties. On merits, […]
The issue was whether third-party diaries using code “DD” can justify 153C action. ITAT held that without clear identification and corroboration, such evidence is insufficient and proceedings are invalid.
The Tribunal held that complete disallowance was excessive despite lack of full documentation. It allowed 50% deduction considering business necessity. Key takeaway: partial evidence can justify partial allowance.
