The issue was whether a delayed Form 10AB filing justified denial of charitable registration. The Tribunal held that bona fide delay due to transitional confusion and CBDT clarifications warranted condonation and fresh adjudication.
The Tribunal held that Section 68 cannot be invoked unless a sum is found credited in the assessees books. In the absence of any such entry, the addition based on an alleged cash loan was deleted.
Emphasising substance over form, the ruling clarifies that genuine charitable trusts should not be denied renewal solely on procedural timelines where reasonable cause exists.
The Tribunal held that additions for completed assessment years under section 153A are invalid when no incriminating material is found during search. Reliance on third-party documents and uncorroborated statements was held insufficient to sustain additions.
The Tribunal ruled that the six-month time limit from commencement of activities applies only to newly formed trusts. Long-standing trusts cannot be denied approval solely on this ground.
The Tribunal examined whether delayed filing of Form 67 can defeat a valid FTC claim. It ruled that Rule 128(9) is directory and FTC cannot be denied when substantive conditions are met.
The CPC taxed interest solely based on Form 26AS despite the assessee following the cash method. The Tribunal ruled that taxation requires verification of receipt and remanded the issue to the AO.
The issue was whether a reassessment notice for AY 2015–16 issued after 31 March 2022 was valid. The Tribunal held the notice time-barred and quashed the entire reassessment proceedings.
The ITAT held that reversal of MSMED Act interest cannot be taxed if the provision was never claimed as a deduction. The matter was remanded for verification, with directions to delete the addition if the claim is confirmed.
The ITAT held that penalty cannot be imposed where a capital loss claim was voluntarily withdrawn during assessment. Since no tax benefit was availed, the case did not attract section 271(1)(c).
