The case involved a Section 263 revision alleging failure to make additions after reopening. The Tribunal ruled that once the AO conducts enquiry and takes a conscious decision, revision is impermissible.
The case examined rejection of registration due to filing Form 10A instead of Form 10AB. The Tribunal held that clerical or procedural mistakes cannot defeat substantive entitlement of old trusts.
The dispute concerned taxability of gains from sale of land located outside municipal boundaries. The Tribunal ruled that such land remains agricultural in nature and is not chargeable to capital gains.
The Assessing Officer disallowed expenses merely alleging cash payments without evidence. The Tribunal ruled that expenses supported by records and banking transactions cannot be disallowed on presumptions.
Levy of interest under sections 234B and 234C on income arising from an APA. Interest was deleted as APA income crystallises only on signing, making advance-tax estimation impossible.
The Tribunal reiterated that procedural delays in uploading Form 10B should not defeat substantive tax exemptions available to charitable trusts. Denial of Section 11 relief merely due to late filing was held to be unjustified where charitable activities were undisputed.
The dispute involved taxing unexplained increases in partners capital in the firms assessment. The Tribunal affirmed that such additions, if any, can only be examined in the hands of partners and not the partnership firm.
The tribunal ruled that cash deposits sourced from recorded cash sales and bank withdrawals were genuine. It held that partial, ad-hoc additions without rejecting books of account are unsustainable.
ITAT Ahmedabad held that addition made on the basis of third-party WhatsApp chat without any incriminating material is unsustainable in law. Accordingly, order of CIT(A) upheld and appeal of revenue is dismissed.
The case examined denial of section 11 exemption at the processing stage due to late filing of Form 10B. The Tribunal ruled that such delay is a curable procedural defect and cannot justify denial of exemption.
