The Tribunal held that preference share investments cannot be treated as loans without supporting evidence. Following earlier decisions and High Court rulings, the transfer pricing adjustment was deleted.
Tribunal ruled that share transactions cannot be treated as loans without proof of exceptional circumstances. Notional interest addition on such re-characterisation was deleted.
The Tribunal examined whether delay in filing appeal was justified under section 249(3). It held that sufficient cause must be interpreted liberally to ensure justice. The key takeaway is that technical delays should not deny statutory appeal rights.
The Tribunal examined whether addition under Section 68 could be made without seized evidence. It held that no addition is permissible in absence of incriminating material. The key takeaway is that search assessments must rely on concrete evidence.
The issue was whether rejection of books and GP estimation was justified due to missing records. ITAT upheld the addition, ruling that failure to produce bills, vouchers, and stock records justified estimation.
The issue was whether repayment of loans through banking channels proves genuineness under Section 68. ITAT Delhi held it does not, ruling that bogus loans remain unexplained even if repaid.
The issue was whether a single satisfaction note for multiple years is valid under Section 153C. ITAT Pune held it invalid, ruling that separate satisfaction per year is mandatory, thereby quashing the entire assessment.
The Tribunal held that audit under section 44AB depends on turnover, not taxability of income. Exempt entities must still comply if limits are exceeded.
DCIT Vs Revanth Challagalla (ITAT Hyderabad) Section 54F Allowed Even When Property Purchased in Sister’s Name – Subsequent Gift Validates Claim In this case, the ITAT Hyderabad upheld the allowance of deduction under Section 54F despite the property being initially registered in the name of the assessee’s sister. The assessee, an NRI, had sold villas […]
The tribunal held that systematic sports training and self-defence instruction to students constitute education under Section 2(15). As activities were charitable and genuine, denial of registration under Sections 12AB and 80G was set aside.
