ITAT Mumbai deleted Section 69 additions as the Revenue relied only on uncorroborated statements and pen-drive data from third parties, violating natural justice. Suspicion alone cannot justify tax additions.
Tribunal rules that Section 54 deduction applies to property purchased outside India before the 2015 amendment, overturning CIT(A) decision.
The ITAT Amritsar remanded the 12A registration application after the CIT(E) ignored documentary proof of charitable activities. The trust must now be reconsidered with full verification of invoices, bank statements, and photographs.
ITAT Ahmedabad held that donations linked to milk supply were compulsory and cannot be treated as corpus contributions under Section 11(1)(d). The trust’s claim for exemption was denied, though a statutory deduction of 15% on revenue was allowed.
The tribunal ruled that funds donated to certain political parties were routed back to the donor, lacking genuineness. Deductions under Section 80GGC were disallowed as a result.
The Tribunal noted that amendments introduced by the Finance Act 2024 permit fresh filings after commencement of activities. The delayed application was remanded to the CIT(E) for consideration under the revised provision.
The Tribunal held that once the assessee’s own ledger reflected a creditor’s write-off, Section 41(1) was automatically triggered. The waiver in books = taxable cessation of liability.
The Tribunal ruled that incidental foreign expenditure does not bar 80G approval, emphasizing that only the main charitable activities’ genuineness matters for registration.
The ITAT set aside the CIT(A)’s order taxing Rs. 10 lakh received from HUF, emphasizing verification of the gift and HUF status before determining taxability under section 56(2)(vii).
Addition of Rs. 2.82 lakh for deemed rent was maintained due to lack of credible evidence from the assessee. Loan interest is to be reconsidered after proper document submission.
