The case examined whether reassessment after four years was valid when the issues were already examined in scrutiny. The Tribunal held the reopening invalid as a mere change of opinion and quashed the reassessment.
Recognising the non-commercial nature of a long-standing charitable trust, the Tribunal condoned the delay. The registration application was sent back for reconsideration on merits.
Where the CIT(A) rejected the appeal only on limitation, the Tribunal intervened. It directed fresh adjudication of the penalty after condoning the 380-day delay.
The Tribunal found that the Commissioner must consider condonation of delay under the amended section 12A. The rejection order was therefore set aside.
The dispute concerned denial of donor approval before finality of charitable registration. The Tribunal held that 80G approval is consequential and cannot be refused while 12AB registration is under re-examination.
The appeal was dismissed ex-parte due to alleged non-compliance by the assessee. The ITAT found that notices were issued to the wrong email despite correct details on record and ordered de novo consideration.
The case clarifies that commission paid to foreign agents for export facilitation abroad cannot be disallowed for non-deduction of tax. Absence of income accrual in India was decisive.
The assessee challenged denial of Section 80P deduction in the order giving effect to the CIT(A)’s directions. The Tribunal ruled that Section 253 permits appeal only against CIT(A) orders, not against implementation orders.
The issue was whether final registration could be denied without granting a proper opportunity of hearing. The Tribunal held that rejection without a show-cause notice violates natural justice and remanded the matter for fresh consideration.
It was held that neither the AO nor the appellate authority provided any factual basis for estimating disallowance. The ruling confirms that estimation must be backed by evidence.
