The Revenue treated a ₹2 crore accumulation disclosed in Form No. 10 as unaccounted income of the trust. The Tribunal ruled that procedural filings cannot substitute evidence of actual income and deleted the addition.
The Tribunal examined whether an incorrect statement of financial transactions filed by a bank could lead to reassessment and addition in the wrong person’s hands. It ruled that admitted reporting errors must be rectified and cannot form the sole basis for taxation.
The Revenue sought to tax software distribution income as royalty despite judicial precedents to the contrary. The Tribunal dismissed the appeal, reaffirming that software sales do not automatically attract royalty taxation.
The Revenue disallowed loan repayments alleging double deduction of charitable expenditure. The Tribunal ruled that documentary evidence established that no double claim had been made and directed deletion of the addition.
The issue was whether expenditure could be disallowed under Section 14A read with Rule 8D when the assessee had not earned any exempt income during the relevant year.
The issue was whether SBN deposits accepted by a co-operative society during demonetisation could be added under Section 68 solely because the notes ceased to be legal tender.
The ITAT Bangalore upheld deduction of ESOP expenditure under Section 37, holding that the liability arising from employee stock options is an ascertained business expense. The Tribunal followed the Karnataka High Court ruling in Biocon Ltd. despite pending appeals before the Supreme Court.
The ruling emphasizes that undisclosed business receipts and stock arising from an existing business cannot automatically be characterized as unexplained income. In the absence of evidence pointing to any other source, the income should be assessed under normal business provisions.
The Tribunal ruled that the guideline value recorded in a registered document is not conclusive for computing capital gains if the assessee proves that a higher amount was genuinely paid. The decision underscores the importance of substantive evidence over mere recitals in the sale deed.
The Tribunal found that the authorities below failed to properly apply the principles governing section 80P deductions relating to nominal members, statutory deposits, and co-operative society investments. The matter was remanded for reconsideration in accordance with settled law.
