The Tribunal held that once business receipts are taxed on an estimated basis, separate additions for payments and assets from the same receipts are impermissible. Only a net-profit estimation was sustained, deleting multiple cascading additions.
The tribunal accepted that allotment confers enforceable capital rights capable of transfer. The ruling clarifies that proceeds from such transfers must be assessed under capital gains, not deemed income.
The Tribunal held that disallowance of interest for non-deduction of TDS cannot be automatic when paid to an NBFC. The Assessing Officer must first verify whether the payee has offered the income to tax.
Levy of interest under sections 234B and 234C on income arising from an APA. Interest was deleted as APA income crystallises only on signing, making advance-tax estimation impossible.
The dispute involved taxing unexplained increases in partners capital in the firms assessment. The Tribunal affirmed that such additions, if any, can only be examined in the hands of partners and not the partnership firm.
The case addressed whether exemption could be disallowed through prima facie adjustment under section 143(1). The Tribunal held such denial impermissible and ordered fresh consideration.
The Tribunal examined whether cost of acquisition could be fixed on assumptions. It held that government-notified MVR rates must be considered and ad-hoc estimates cannot replace statutory valuation methods.
The Tribunal held that rejection of the appeal without a reasoned order violated appellate duties. All issues were restored for de novo consideration with directions to ensure due opportunity.
Authorities taxed refund interest as business income by linking it to earlier PE years. The Tribunal ruled that without a PE in the year of receipt, the income cannot be treated as effectively connected and must enjoy DTAA relief.
The Tribunal emphasized that exemption cannot be denied on assumptions. It restored the case to the AO for limited verification, reinforcing evidence-based assessment by the Income Tax Appellate Tribunal.
