Professional fees and foreign branch expenses incurred by a strategic investment company were allowable under Section 37(1) in the absence of any finding that the expenditure was excessive, unreasonable
The Tribunal held that receipts already offered under the presumptive scheme cannot be taxed again as unexplained money. Once income is declared under section 44AD and supported by surrounding facts, section 69A has no application.
The tribunal held that assessments selected for limited scrutiny cannot include additions on unrelated issues without formal conversion to complete scrutiny. All such additions were set aside as being without jurisdiction.
The case examined the tax treatment of purchases from alleged accommodation entry providers. The Tribunal held that at best, only the profit element embedded in such purchases can be brought to tax.
The Assessing Officer disallowed interest expenditure in an ex parte order under section 144. The Tribunal ruled that once evidence shows a clear link between interest paid and interest earned, the deduction must be allowed.
The application was rejected only on limitation without examining merits. The Tribunal ruled that bona fide delay must be condoned and eligibility under section 80G(5) examined afresh.
The Tribunal held that overseas shares acquired from reinvested dividends cannot be taxed as undisclosed assets when the source is known and accepted. Mere omission of dividend income does not trigger the Black Money Act’s harsh provisions.
The Tribunal held that revision under section 263 is invalid where the Assessing Officer has already conducted enquiries and taken a conscious view. Mere inadequacy of enquiry does not justify revision.
The Tribunal held that cash withdrawn from disclosed bank accounts and duly recorded in books cannot be treated as unexplained money merely due to doubts on utilisation, in the absence of adverse evidence.
The Tribunal confirmed that licence fees for use of immovable property fall under house property income. It emphasized that once included in computation, the same amount cannot be added again.
