The Delhi High Court held that the issues raised by the Revenue were either covered by binding precedents or based on factual findings of the ITAT. It dismissed the appeal after finding no substantial question of law for consideration.
The ITAT Mumbai held that the rejection of the assessees certified segmental results was unsupported by cogent material and based on surmises. It directed the TPO to consider the audited segmental accounts while benchmarking the international transaction.
The Tribunal ruled that a penalty notice lacking a specific allegation of under-reporting, misreporting, or the applicable clause under Section 271AAB is legally defective. It held that such notices violate the requirement of providing a meaningful opportunity of defence.
ITAT condoned the filing delay and remanded the case to the CIT(E) to examine whether the trust satisfies all 80G requirements.
ITAT held Form 10AB was filed beyond the prescribed time but permitted the trust to seek CBDT condonation under Section 119(2)(b) before merits are examined.
ITAT held that Section 154 cannot be used where applicability of Section 167B requires factual examination, making the issue debatable and not a mistake apparent.
ITAT held that once Form 10IE is validly exercised and not withdrawn, it continues for later years. AO was directed to grant Section 115BAC benefit.
ITAT Mumbai held that a deduction claim supported by prevailing judicial precedents cannot attract Section 270A penalty merely because a later retrospective amendment made the claim inadmissible. The penalty for under-reporting of income was deleted.
ITAT deleted the Section 68 addition after holding that the assessee fully established the lender, source of funds and genuineness.
ITAT held that substantial construction and structural improvements satisfied Section 54F. AO was directed to allow the deduction.
