The Tribunal held that delay due to lack of awareness and administrative oversight constituted sufficient cause. It set aside the rejection as the condonation request was not considered and remanded the case.
The tribunal held that reassessment fails if no addition is made on the issue cited for reopening. Additions on unrelated grounds were declared beyond jurisdiction.
The Tribunal held that tenancy supported by rent receipts, bills, and agreements cannot be treated as a sham. It upheld exemption under Section 54F on surrender of tenancy rights.
The Tribunal held that absence of charitable activities at the time of application does not make a trust non-genuine. The key takeaway is that proposed activities and charitable objects must be considered for registration.
The Tribunal held that interest on borrowed funds used to acquire a foreign company in the same line of business is allowable under Section 36(1)(iii). It found that the acquisition was driven by commercial expediency and business expansion.
The tribunal ruled that compensation under a government-approved restructuring scheme qualifies as retrenchment. It allowed full tax exemption under Section 10(10B).
The Tribunal upheld deletion of addition as seized loose sheets lacked key details and no supporting evidence proved unaccounted sales. Reliance solely on such documents was held insufficient.
The tribunal held reopening invalid where actual escaped income was below ₹50 lakh. It clarified that jurisdiction depends on real income, not transaction value.
The Tribunal ruled that revision under Section 263 requires examination of approval granted under Section 153D. Without establishing any defect in such approval, the assessment cannot be termed erroneous. The decision limits arbitrary revision powers.
The Tribunal held that additions cannot be sustained merely on third-party Excel sheets and statements. It ruled that absence of independent evidence and denial of cross-examination renders such additions invalid.
