The dispute concerned denial of exemption on the ground of alleged business activity. The Tribunal held that once registration under Section 12AA stood restored, exemption under Sections 11 and 12 could not be denied.
The Tribunal held that once business receipts are taxed on an estimated basis, separate additions for payments and assets from the same receipts are impermissible. Only a net-profit estimation was sustained, deleting multiple cascading additions.
The tribunal accepted that allotment confers enforceable capital rights capable of transfer. The ruling clarifies that proceeds from such transfers must be assessed under capital gains, not deemed income.
The issue was whether cash deposited during demonetisation could be taxed as unexplained money. The Tribunal held that prior withdrawals from the bank sufficiently explained the deposits, warranting deletion of the addition.
Where updated cash books explained the cash found and no defects were pointed out, additions under section 69A were held unsustainable. Substantiation with regular books prevailed over search-time snapshots.
The issue concerned reassessment initiated through a non-faceless notice despite a binding notification. The ruling confirms that violation of the faceless framework vitiates reassessment proceedings.
The Tribunal held that reassessment based on a notice issued by the wrong authority cannot survive in law. The decision highlights strict adherence to procedural requirements under the faceless regime.
The Tribunal upheld the CIT(A)’s power to remand an ex-parte assessment for fresh adjudication. It ruled that such action was within jurisdiction, leading to dismissal of the Revenue’s appeal.
The issue was whether penalty could survive after the assessment order was set aside. The Tribunal held that once the basis of the addition is extinguished, penalty under Section 271(1)(c) cannot be sustained.
The Tribunal dismissed the Revenue’s appeal, noting that transferred employees performed functions entirely for the assessee. Salary expenditure was held to be incurred for business purposes.
