The assessee had fully disclosed the share transactions and claimed exemption under Section 10(38) in the original return. The ITAT ruled that reopening was unsustainable because the reasons recorded did not demonstrate how any income had actually escaped assessment.
The Tribunal held that AY 2010-11 was outside the permissible ten-year assessment block computable under Section 153A. Applying the Delhi High Court’s interpretation in Ojjus Medicare, it found the notice itself invalid. As a result, the assessment proceedings were quashed and the appeals were allowed.
The Tribunal held that donations qualifying under Section 80G do not become ineligible merely because they are incurred as part of CSR obligations. The deduction was allowed following earlier decisions in the assessee’s own case.
The Tribunal held that disallowance of 20% of total purchases was unsustainable where the Assessing Officer had accepted sales, stock records, and quantitative details. Mere non-service of notices under Section 133(6) could not justify treating all purchases as bogus.
The Tribunal found that bank documents showing repayment of the loan were relevant for deciding the Section 68 issue. The matter was remanded to the Assessing Officer for fresh examination.
The Delhi ITAT upheld deletion of a ₹14.20 crore addition under Section 68, holding that the AO relied on old search findings and failed to bring any direct evidence against the assessee’s loan transactions.
ITAT Delhi held that high sea sales could not be treated as non-genuine where customs approvals, sale agreements, and delivery records established the transactions. The Tribunal deleted the ₹59.11 crore addition and ruled that Section 68 could not apply to recovery of sale consideration.
ITAT Delhi held that the PCIT exceeded jurisdiction by introducing issues not mentioned in the Section 263 show-cause notice. The revision order was quashed for travelling beyond the scope of the proceedings.
The ITAT held that registration under Sections 12AA/12AB cannot be cancelled when the trust continues to genuinely carry out its educational objects. Alleged fund diversion and related-party transactions must be examined during assessment and taxation proceedings instead.
The ITAT held that leave encashment of ₹6.97 lakh was fully exempt as it fell within the revised ₹25 lakh ceiling under Notification No. 31/2023. The appeal was allowed accordingly.
