The assessee alleged denial of opportunity and improper handling of evidence. The Tribunal agreed that the appellate order was passed without due consideration of records and remand findings. The matter was sent back for fresh adjudication in accordance with law.
Lenders had confirmed loans in response to statutory notices, yet additions were made. The Tribunal upheld deletion by CIT(A), stressing the importance of uncontroverted confirmations. The ruling reinforces evidentiary discipline in Section 68 cases.
The Tribunal held that TCS credit cannot be denied when tax was collected from the assessee, even if the collector failed to deposit it.
The Tribunal ruled that a mere disallowance of depreciation, with full disclosure of facts, does not attract penalty under Section 270A.
Revenue counted limitation from the third-party search date, while the assessee argued it should start from document handover. ITAT Delhi agreed, holding the assessment outside the six-year period, thereby voiding it.
The Tribunal found that satisfaction under Section 153C was recorded long after the search and document transfer. Applying binding judicial precedent, ITAT ruled that the assessment was barred by limitation and therefore null and void.
The issue was whether accumulated income could be taxed merely because it was not spent exactly for the purpose stated in Form-10. ITAT Delhi held that as long as funds are applied toward charitable educational objects, technical lapses or non-intimation to the AO cannot defeat exemption under Section 11.
The Tribunal found that alleged cash payments lacked any agreement, bank trails, or confirmation from recipients, making the addition legally untenable. ITAT emphasized adherence to evidentiary standards under Section 65B and deleted the addition entirely.
Jaipur Tribunal observed that the son had no independent income, and the purchase was made solely from the assessee’s funds. Consequently, restriction of exemption to 50% by the CIT(A) was set aside, confirming full Section 54F relief.
ITAT Jaipur held that withdrawing approval under section 10(23C)(vi) of the Income Tax Act not justified in absence of any corroborative evidence of personal benefit of trustees and misuse of funds. Accordingly, appeal allowed and registration u/s. 10(23C)(vi) restored.
