The Tribunal held that corpus donations cannot be denied merely due to technical lapses like student collection or minor PAN errors. Donor intent and consistent treatment in books were sufficient to allow exemption under section 11(1)(d).
The ruling clarifies that mere reproduction of third-party information alleging disproportionate assets is insufficient. The Assessing Officer must clearly identify escaped income and apply independent reasoning.
The Tribunal noted that no construction investment occurred during the year under appeal. Accordingly, no addition for unexplained investment could be sustained in that assessment year.
It was ruled that section 80G(5B) expressly permits limited religious expenditure up to 5% of total income. Denial of approval without examining actual expenditure was held to be legally unsustainable.
The Tribunal held that where purchases are not disputed and books are not rejected, the entire sale consideration cannot be added as unexplained income. Since the assessee had already offered profits to tax, the addition was deleted.
The tribunal held that where the Assessing Officer conducted exhaustive enquiries and applied his mind in a 153C assessment, revision under section 263 is invalid. A mere change of opinion cannot justify reopening a concluded assessment.
The Tribunal upheld deletion of an ad-hoc expense addition where the Assessing Officer failed to point out defects in audited accounts. Proper documentation shifted the burden back to the tax authority.
The decision reiterates that when books of account, sales, and inventory are accepted, purchase disallowances cannot be made mechanically. Suspicion cannot replace proof in tax proceedings.
The decision underscores that ignoring audited disclosures, ledgers, and salary records violates principles of natural justice. Once actual payment is proved, gratuity deduction must be allowed.
The Tribunal held that once the assessee proves identity, genuineness, and source through documents and bank records, the burden shifts to the Revenue. Without rebuttal of evidence, addition under Section 68 cannot survive.
