The Tribunal ruled that the disallowance of interest on the ground of mixed-funds usage could not be sustained without allowing the AO to verify supporting documents. The matter was remitted to ensure a fresh and fair assessment in accordance with law.
The tribunal examined whether lack of expenditure justified rejection of 12AB and 80G applications. It ruled that a newly formed trust cannot be denied registration merely because it has not yet commenced activities.
The tribunal ruled that rejecting the assessee’s request for virtual hearing violated natural justice. The matter was restored for fresh consideration to ensure fair opportunity to present submissions.
Delhi ITAT remands the case to CIT(A) for fresh adjudication after ex-parte dismissal. Tribunal emphasized that sufficient hearing opportunity must be granted before rejecting appeals.
The Tribunal upheld the addition because the assessee could not prove the creditor’s identity, financial capacity, or the genuineness of the ₹50 lakh credit. Defective confirmation, NIL income of the creditor, and absence of source details weighed against the assessee. The ruling emphasizes that Section 68 requires clear, credible evidence.
ITAT upheld deletion of ₹3.31 crore addition under Section 69, noting full disclosure of foreign assets and sufficient income. Revenue cannot levy additions where investments are legitimate and documented.
ITAT upheld rejection of books under Section 145(3) due to incomplete records but reduced estimated net profit from 8% to 2%. Historical profit trends guided a fairer assessment.
ITAT Delhi remands addition of ₹78.12 lakh under Section 68, allowing assessee to prove lessees’ agricultural use. Proper verification and opportunity are essential before denying Section 10(1) exemption.
ITAT held that reassessment notices issued after the surviving period, as clarified by Rajeev Bansal, are time-barred for AY 2015-16. The ruling emphasizes that procedural compliance with limitation periods is mandatory, even if notices are issued under unamended law.
ITAT Delhi held that a single Section 153D approval for multiple assessees and years is impermissible, rendering all 153A and 153C assessments void ab initio.
