The Tribunal held that employee stock option plan costs are allowable revenue expenditure. Following binding High Court precedent, the ₹93 lakh disallowance was deleted.
ITAT held that reassessment notices issued after the permissible limitation period were invalid. Applying the Supreme Court’s ruling in Rajeev Bansal, all proceedings were quashed as being beyond jurisdiction.
The Tribunal held that the Assessing Officer failed to apply amended provisions taxing interest on enhanced compensation. Revision under Section 263 was upheld as the assessment was erroneous and prejudicial to revenue.
The Tribunal sustained reassessment based on search information but faulted the disallowance of political donations. The key takeaway is that additions cannot rest solely on untested third-party statements without cross-examination.
The Tribunal ruled that Section 14A cannot be invoked where borrowed funds were not used to earn exempt income. Disallowance was deleted after finding investments were made from interest-free funds.
ITAT held that additions under Section 68 cannot be made for an unabated year unless incriminating material is found during search. Share premium additions based only on books and enquiries were rightly deleted.
The Tribunal upheld exemption where the assessee invested the entire capital gain within time but possession was delayed due to builder-related litigation. The ruling confirms that investment, not possession, is the key requirement under Section 54F.
The Tribunal held that reassessment was invalid as the statutory sanction under Section 151 was granted mechanically. Mere use of the word Approved does not show application of mind and vitiates the entire proceedings.
The Tribunal ruled that ad hoc disallowance is unsustainable when books are not rejected. Disallowance was reduced to 8% based on facts and past practice.
The Tribunal held that sanction for reopening was granted mechanically and without independent application of mind, as required under Section 151. An undated and non-speaking approval vitiated the entire reassessment proceedings.
