ITAT held that an unexplained delay of over 11 years cannot be condoned without valid reasons. The appeal was dismissed as no sufficient cause was proved.
ITAT held that late filing of Form 67 is only a procedural lapse and not a ground to deny FTC. The matter was remanded for verification and grant of eligible credit.
The issue was whether reassessment can survive when no addition is made on the stated reasons for reopening. The Tribunal held that such reassessment is invalid, and the AO cannot make unrelated additions.
The case examined whether share premium could be taxed without proof of unaccounted funds. The Tribunal held that Section 56(2)(viib) cannot be invoked without establishing such inflow, leading to deletion of the addition.
The issue was whether share capital addition could be sustained without seized evidence. The Tribunal held that in absence of incriminating material, the addition under Section 68 is invalid.
The issue was whether additions could be made in unabated assessments without incriminating material. The Tribunal held that such additions are invalid, relying on Supreme Court precedent.
The Tribunal examined whether addition under Section 68 could be made without seized evidence. It held that no addition is permissible in absence of incriminating material. The key takeaway is that search assessments must rely on concrete evidence.
ITAT Chennai held once the AO has conducted inquiry, examined replies and adopted a legally sustainable view, the same cannot be treated as erroneous. Accordingly, invocation of revisionary jurisdiction under section 263 of the Income Tax Act is not sustainable in law.
The Tribunal held that absence of charitable activities at the time of application does not make a trust non-genuine. The key takeaway is that proposed activities and charitable objects must be considered for registration.
The Tribunal held that corpus donations received with specific directions are capital in nature and cannot be included in annual receipts. Since actual receipts were below ₹1 crore, exemption was allowed.
