It was held that sale consideration from trust property, when donated to charitable institutions, cannot be taxed as income. The ruling confirms protection for genuine charitable application of capital receipts.
The issue was whether bank credits already offered as income in an HUF’s return could again be taxed in the individual’s hands. ITAT held that double taxation is impermissible and directed the AO to verify HUF records before making any addition.
Additions were made solely because the trust failed to submit details during assessment and appeal. ITAT set aside the assessments for fresh adjudication, stressing that substantive claims should be decided on merits rather than procedural lapses.
ITAT held that Section 153C cannot be invoked where the satisfaction/hand-over date is after 01.04.2021, quashing multiple assessments framed thereafter. The ruling follows the Madras High Court and reinforces Section 153C(3)’s statutory bar.
The Tribunal held that unexplained cash credit addition cannot survive once identity, genuineness, and creditworthiness are established through documentary evidence. The key takeaway is that mere low income of creditors is insufficient without contrary investigation.
The Tribunal held that delayed responses to statutory notices do not attract penalty when full compliance is ultimately made and accepted before assessment completion. The key takeaway is that penalties cannot be imposed mechanically in the absence of willful default.
Tribunal held that cash found and seized cannot be treated as unexplained when it is fully reflected in audited books and not disproved by tax authority. Additions under Section 69A cannot rest on suspicion alone.
ITAT Hyderabad held that final assessment order passed under section 143(3) of the Income Tax Act by AO beyond the time limit provided under Section 153(1) of the Income Tax Act is barred by limitation. Accordingly, appeal of assessee allowed.
The Tribunal ruled that dismissing appeals in limine without examining reasons for delay was improper. It restored the matters for fresh consideration, stressing that procedural lapses should not defeat substantive justice.
The Tribunal held that post–Finance Act, 2024, an 80G application can be filed any time after commencement of activities. Rejection solely for delay was set aside and the application was restored for fresh consideration.
