The Tribunal held that a final assessment passed without giving effect to binding DRP directions violates section 144C. Such an order is void ab initio and cannot be sustained once the statutory time limit has expired.
It was ruled that the date of recording the satisfaction note is the deemed search date for a non-searched person. The ten-year limitation must be counted from this date, not from the original search.
The Tribunal deleted both substantive and protective additions made across multiple years on the same alleged receipts. It held that such duplication results in impermissible multiple taxation of identical amounts.
The Tribunal held that discounts given to stockists in pharmaceutical distribution are part of sale transactions on a principal-to-principal basis. As no commission was paid, TDS under section 194H was held inapplicable.
The Tribunal held that where income is offered to tax on receipt basis, TDS credit must be granted in the same year despite timing differences arising from accrual-based deduction by clients.
ITAT held that an old trust could not be denied five-year registration merely due to technical restrictions in the online filing system. Provisional registration was set aside and fresh processing was ordered.
The Tribunal held that CSR expenditure disallowed under Section 37 does not bar deduction under Section 80G. Donations to eligible institutions remain deductible unless specifically excluded by law.
The Tribunal held that a common, perfunctory sanction under Section 153D is invalid. The key takeaway is that lack of independent application of mind vitiates search assessments entirely.
The ITAT held that equipment received free of cost for testing purposes does not constitute a taxable business benefit. It ruled that once the receipt itself is not taxable, no notional mark-up can be added.
The case examined denial of section 11 exemption at the processing stage due to late filing of Form 10B. The Tribunal ruled that such delay is a curable procedural defect and cannot justify denial of exemption.
