In the absence of proper compliance with Section 65B and failure to establish a clear chain of custody, the digital evidence relied upon by the Revenue lacked legal admissibility and evidentiary value.
Tribunal held that GST-based turnover differences cannot be taxed again when income was already recorded in prior years and notional interest recognized under IND-AS cannot be taxed unless it actually accrues.
Tribunal held that technical handling income is covered under Article 8 of India–France DTAA. It ruled that such income arises from operation of aircraft in international traffic and is not taxable in India.
The Tribunal held that protective additions cannot be sustained without establishing the assessee as the actual beneficiary of cash credits. It upheld deletion where ownership was not proven.
The Tribunal held that the Assessing Officer erred in fully rejecting the assessee’s explanation linking cash deposits to business sales. However, due to incomplete substantiation, a limited addition of ₹8 lakh was sustained.
The Tribunal allowed deduction of royalty paid for use of a logo, noting that no specific defect was found in the supporting evidence. It held that the expenditure could not be disallowed merely on grounds of justification without examining its business purpose.
When an entity served both its members and the public, the dominant object test applies. If the regulatory functions lead to borrower protection and financial stability for low-income groups, the GPU status was maintainable.
ITAT held that share capital addition cannot be sustained where identity, genuineness, and creditworthiness of investors are supported by documents. The Tribunal found no defect in CIT(A)’s order deleting most of the addition.
The Tribunal ruled that an unregistered agreement does not invalidate exemption if possession is taken and payment is made. The term purchase under Section 54 was interpreted broadly.
The Tribunal held that MMR cannot be applied where income is modest and statutory conditions are not met. It directed recomputation without applying higher tax rates.
