ITAT held that an old trust could not be denied five-year registration merely due to technical restrictions in the online filing system. Provisional registration was set aside and fresh processing was ordered.
The addition on shares contributed to a family trust was deleted as the trust was exclusively for the benefit of relatives. Section 56(2)(x) does not apply where the statutory exemption conditions are satisfied.
The ITAT held that when reassessment is annulled for jurisdictional defects under the faceless regime, the connected concealment penalty cannot stand.
The tribunal held that once penalty is imposed for non-maintenance of books, a second penalty for non-audit cannot be levied. Levy of section 271B was held to be impermissible double penalisation.
The Tribunal clarified that approval under section 153D is an administrative safeguard and need not contain elaborate reasoning. Allegations of mechanical approval fail without concrete evidence of non-application of mind.
The tribunal held that assessment under section 153C cannot be initiated without seized material belonging to or relating to the assessee. Third-party statements and assumptions, without incriminating evidence, were held insufficient to confer jurisdiction
The Tribunal held that reassessment proceedings are invalid where notices are issued by the Jurisdictional AO instead of the Faceless AO. Non-compliance with the faceless scheme renders the entire process void.
The Tribunal ruled that reopening beyond six years is invalid without a recorded satisfaction of undisclosed assets exceeding ₹50 lakh. The takeaway is strict compliance with the fourth proviso to section 153A is mandatory.
The issue was whether third-party diaries and loose papers could establish receipt of unaccounted income. The Tribunal ruled that such papers, without authorship verification or corroboration, cannot fasten tax liability.
The issue was whether utilisation of corpus donations for expenditure converts them into taxable income. The Tribunal held that corpus retains its exempt character when used as per donor directions and trust deed.
