The tribunal ruled that reassessment beyond four years is barred when reasons do not allege failure to disclose material facts. Mere suspicion of escaped income is insufficient to override the statutory limitation.
ITAT held that CPC cannot deny charitable exemption under section 11 through section 143(1) adjustment without issuing prior intimation. The matter was restored to the AO for fresh examination after due opportunity.
The ITAT held that unsupported DCF valuation could not justify high share premium. The addition under Section 56(2)(viib) was restored after setting aside the appellate relief.
The Tribunal held that a short delay caused by hospitalisation must be condoned when supported by evidence. Procedural lapses cannot defeat substantive justice.
The ITAT condoned a 66-day delay after accepting that the trust was unfamiliar with the income-tax e-filing system. The matter was restored for fresh consideration with costs imposed.
The ITAT held that reopening an assessment after four years without any new tangible material is invalid. A reassessment based merely on re-examining earlier facts was struck down as a change of opinion.
ITAT Bangalore held that once the genuineness of the building construction expenditure is proved, the consequential claim of depreciation on such genuine assets cannot be denied to trust since depreciation was claimed only on actual assets used for charitable purpose.
ITAT Bangalore held that at the relevant time co-founder of Flipkart stayed in India for 141 days and balance days in other countries. Hence, assessee is an Indian national and thus the appeal of the assessee is dismissed.
ITAT Mumbai held that disallowance of interest expenditure under Rule 8D(2)(ii) of the Income Tax Rules is not sustainable since the assessee’s own interest-free funds were substantially higher than the investment. Accordingly, appeal of revenue dismissed and order of CIT(A) upheld.
The ruling addressed whether a delayed application could survive after statutory change. The Tribunal directed fresh consideration by applying the liberalized timeline introduced by Finance Act, 2024.
