The tribunal examined whether gold jewellery seized during police interception could be taxed as unexplained solely based on a statement recorded under enquiry. It held that additions fail where later evidence shows the assessment relied on weak corroboration and inconsistent reasoning.
The issue was whether revision under section 263 was valid for multiple expense claims. The Tribunal held that since the Assessing Officer had examined issues and adopted a plausible view, revision was unsustainable.
The case examined the correct tax rate for a trust formed exclusively for employees’ benefit. The Tribunal held that such trusts are taxable at normal AOP rates under section 164(1)(iv).
The dispute concerned whether reimbursements from an associated enterprise justified a transfer pricing adjustment using the profit split method. The Tribunal set aside the adjustment, directing a fresh FAR analysis before determining ALP.
Appeals were dismissed earlier as time-barred despite sustained efforts by the assessee through grievances. The Tribunal ruled that absence of negligence and bona fide conduct warranted condonation of long delay.
The Tribunal rejected estimated additions based on alleged circular trading due to lack of seized material or cash trail. The key takeaway is that suspicion and presumptions cannot replace evidence in search assessments.
ITAT Hyderabad held that notices under Section 148 issued on 01.04.2021 without following mandatory Section 148A procedures are invalid. The Tribunal quashed reassessment orders, emphasizing that procedural compliance is jurisdictional and essential.
The Tribunal held that earning income as a percentage of hospital turnover is commercial, not charitable. Section 80G approval was rightly denied for lack of genuine charitable application.
ITAT Mumbai held that TDS credit duly reflected in Form 26AS cannot be denied just because of some procedural lapse. Accordingly, order is set aside and the present appeal is allowed.
The Tribunal found that CIT(A) erred by linking the protective addition to another company. The assessment was remanded for correct identification of the beneficiary.
