The case involved an addition based on AIR information regarding a property transaction. The Tribunal deleted the addition after finding that the assessee’s documentary evidence remained unchallenged by the department.
The tribunal held that the safe harbour limit applies to valuation determined by the DVO, not just stamp duty value. It ruled in favour of the assessee as the variation was within 10%.
The Tribunal held that the maintainability of the appeal must be based on the correct tax effect and not erroneous figures in Form 36. Since the actual tax effect was below the CBDT threshold, the appeal was dismissed, reinforcing strict adherence to monetary limits.
The Tribunal held that delay due to lack of awareness and administrative oversight constituted sufficient cause. It set aside the rejection as the condonation request was not considered and remanded the case.
The tribunal held that reassessment fails if no addition is made on the issue cited for reopening. Additions on unrelated grounds were declared beyond jurisdiction.
The Tribunal held that tenancy supported by rent receipts, bills, and agreements cannot be treated as a sham. It upheld exemption under Section 54F on surrender of tenancy rights.
The Tribunal held that absence of charitable activities at the time of application does not make a trust non-genuine. The key takeaway is that proposed activities and charitable objects must be considered for registration.
The Tribunal held that interest on borrowed funds used to acquire a foreign company in the same line of business is allowable under Section 36(1)(iii). It found that the acquisition was driven by commercial expediency and business expansion.
The tribunal ruled that compensation under a government-approved restructuring scheme qualifies as retrenchment. It allowed full tax exemption under Section 10(10B).
The Tribunal upheld deletion of addition as seized loose sheets lacked key details and no supporting evidence proved unaccounted sales. Reliance solely on such documents was held insufficient.
