The Tribunal upheld the deduction of interest expenditure after finding that the loan was utilized wholly for business activities. Once business use was established, the deduction could not be denied merely on technical grounds.
The Tribunal held that a university is substantially financed by the Government only when Government grants exceed 50% of total receipts during the relevant previous year. Since the prescribed threshold was not met, the exemption was denied.
ITAT Ahmedabad held that unsecured loan additions could not be sustained where the assessee furnished confirmations, bank statements, and tax records, and the Revenue failed to establish any cash trail or nexus with alleged accommodation entries.
The Tribunal held that Section 43B cannot be invoked where the assessee has not claimed the GST liability as a deduction. Since the amount was not debited to the profit and loss account, the disallowance was deleted.
The Tribunal held that once a Section 35D claim was accepted in earlier years, it could not be disallowed in the final amortization year without disturbing the original allowance. The disallowance of preliminary expenses was therefore delete
ITAT Bangalore ruled that rejection of an 80G registration application merely for quoting the wrong section code violated principles of natural justice. The authority was directed to consider the corrected application on merits.
Tribunal could not recall and restore an appeal dismissed ex parte under Rule 24 of the ITAT Rules, 1963, when assessee filed miscellaneous applications after a lapse of 14 years without establishing sufficient cause for non-appearance, and where service of the original order was presumed under section 27 of the General Clauses Act as the term “afterwards” used in Rule 24 of the ITAT Rules provided procedural flexibility but did not grant an indefinite timeline.
Whistleblower reward of Rs. 8.16 crore received by the assessee from the U.S. SEC for providing information and substantial assistance in enforcement proceedings was a taxable revenue receipt.
The Jaipur ITAT held that reopening under Section 147 cannot be sustained where the Assessing Officer merely relies on information from the Investigation Wing without forming an independent belief. The reassessment proceedings were held invalid for lack of independent application of mind.
The Jaipur ITAT held that reopening of assessment cannot be based solely on information received from the Investigation Wing without independent application of mind. The reassessment proceedings were quashed as the Assessing Officer failed to form his own satisfaction.
