The Tribunal ruled that the PCIT lacked jurisdiction to revise an assessment when the very issue was already under challenge before the appellate authority. Parallel revision proceedings were held to be impermissible.
Additions based on survey-time valuation of machinery were deleted as the Assessing Officer had not rejected the books of account. Prior binding orders in the same case were followed, reaffirming settled law.
The issue was whether late filing of Form 10AB mandates rejection of registration. The Tribunal held that bona fide delay can be condoned and remanded the matter for fresh consideration.
The tribunal held that indexed cost of acquisition must be allowed while computing LTCG of a charitable trust. Indexation under Section 48 applies even when gains are treated as application of income under Section 11(1A).
The tribunal deleted penalty where the quantum addition was restricted to an estimated profit element. It held that penalty cannot survive without a clear finding of concealment.
The Tribunal affirmed restricting Section 14A disallowance to the actual exempt income earned. It also held the Finance Act, 2022 explanation to be prospective, protecting taxpayers for earlier years.
The dispute involved additions made despite small variations between agreement value and stamp duty value. The Tribunal ruled that differences within 10% are immune from Section 43CA, granting relief for genuine transactions.
The ruling clarifies that CSR-related disallowance under Section 37(1) applies only from AY 2015-16 onwards. For earlier years, expenses with a business nexus remain deductible.
Relying on jurisdictional High Court precedent, the Tribunal ruled that penalty is unsustainable when additions are based on estimation. The decision reinforces limits on penalty in such cases.
The ruling addressed conflicts between documentary proof of loans and third-party allegations of accommodation entries. The Tribunal held that unsupported allegations cannot override evidence establishing genuine loan transactions.
