The Tribunal ruled that dismissing appeals in limine without examining reasons for delay was improper. It restored the matters for fresh consideration, stressing that procedural lapses should not defeat substantive justice.
The Tribunal held that post–Finance Act, 2024, an 80G application can be filed any time after commencement of activities. Rejection solely for delay was set aside and the application was restored for fresh consideration.
The ruling found that the authorities failed to examine party-wise payment limits before disallowing expenses for alleged TDS default. Key takeaway: threshold verification is essential before invoking section 40(a)(ia).
The ruling declares reassessment void where notices were not issued through the faceless mechanism post-29.03.2022. Lesson: non-compliance with section 151A vitiates reopening.
The Tribunal held that where sales are accepted and purchases are supported by documents, the entire purchase value cannot be added as bogus. Only the embedded profit element can be taxed, not the full expenditure.
The case addressed the legality of reopening an assessment when the notice was not issued through NFAC. Following jurisdictional High Court rulings, the Tribunal ruled that such deviation vitiates the entire reassessment process.
Cash deposits arising from routine business collections cannot be wholly treated as unexplained income. The ruling confirms that estimations must reflect the nature of the taxpayer’s business.
The Tribunal examined how brought-forward losses should be computed for MAT purposes. It held that losses as on the end of the preceding year must be considered, not figures altered during the assessment year.
The Tribunal held that Section 56(2)(viib) could not be applied once the assessee qualified as a company in which the public are substantially interested. The ruling clarifies that the charging provision itself fails where statutory exclusion applies.
The Tribunal held that mere facilitation of third-party payments to an associated enterprise does not constitute a service. As no value addition was involved, applying a markup on reimbursements was found unsustainable.
