ITAT held that late filing of Form 67 is only a procedural lapse and not a ground to deny FTC. The matter was remanded for verification and grant of eligible credit.
The case involved additions made solely on an Excel sheet and a third-party statement alleging cash payments. The Tribunal ruled that such unverified material, without independent evidence, cannot justify additions.
The issue was whether penalty applies when a bogus donation claim is withdrawn after detection. The Tribunal held that post-detection withdrawal is not voluntary, and penalty for misreporting was rightly imposed.
The issue was whether reassessment can survive when no addition is made on the stated reasons for reopening. The Tribunal held that such reassessment is invalid, and the AO cannot make unrelated additions.
ITAT held that reassessment without issuing notice under Section 143(2) is invalid, even if return was filed late. The ruling emphasizes that issuance of notice is mandatory and absence of it makes the assessment void.
ITAT ruled that deduction under Section 54F can be raised during reassessment if it relates to the income under scrutiny. The case clarifies that reassessment scope includes such connected claims.
The Tribunal held that ad hoc disallowance of labour expenses without concrete evidence is unsustainable. It ruled that suspicion alone cannot justify additions when proper documentation exists.
The tribunal found that STCG may have been counted twice, inflating taxable income. It directed verification and recomputation by the Assessing Officer. The ruling highlights correction of computational errors.
The issue involved additions for alleged cash payments based on third-party data and statements. ITAT deleted the additions, holding that no independent evidence or cross-examination opportunity was provided.
The tribunal set aside excessive addition by recognizing both the allotment agreement and joint ownership. It directed proportionate taxation and correct valuation basis. The ruling promotes fairness in assessments.
