The ITAT ruled that section 151 approval must strictly correspond to the recorded reasons for reopening. Any factual inconsistency reflects non-application of mind and collapses the reassessment at inception.
ITAT acknowledged that ECB interest was fixed and consistently accepted in earlier years but adopted a marginally revised rate after the assessee’s voluntary settlement to close the dispute.
The Tribunal ruled that section 263 cannot be invoked merely because no addition was made during reassessment. When the AO conducts proper enquiries and accepts the explanation, revision fails for lack of error and prejudice.
The Tribunal rejected the Revenue’s claim that breed development expenses are capital merely due to long-term benefits. What matters is business purpose and operational nexus, not incidental endurance.
The issue was whether the entire Section 80JJAA deduction could be rejected when some employees failed the 240-day condition. The Tribunal held that only ineligible employees’ costs can be disallowed, not the whole claim.
The tribunal held that reassessment beyond three years is invalid when alleged escaped income is below Rs. 50 lakh. Notices issued contrary to section 149 after the 2021 amendments were quashed for lack of jurisdiction.
The tribunal held that invoking Section 115BBE on survey-related excess stock was legally unsustainable for AY 2015-16. The addition was therefore liable to be taxed at normal rates.
The tribunal held that non-filing of return within the due date disentitled the assessee from deduction under section 80P due to section 80AC. Consequently, lower profit claims based on accounts were rejected.
The Tribunal held that GST paid during the relevant year is allowable under Section 43B even if it relates to an earlier period. Since the amount was actually paid and not claimed earlier, disallowance was unjustified.
The tribunal held that commission paid to overseas agents was a normal business expense and not taxable in India. Since no TDS was required, disallowance under section 37(1) was unsustainable.
