ITAT Pune deletes ₹4.83 lakh penalty under Section 271(1)(c), holding that a bona fide difference in share valuation methods (NAV vs DCF) does not amount to furnishing inaccurate particulars; mere rejection of a claim cannot trigger penalty.
ITAT Pune rules that delay in filing Form 67 is a procedural lapse and cannot deny Foreign Tax Credit under Section 90; directs AO to grant ₹2.74 lakh FTC after verification, upholding substantive relief despite delay.
ITAT Pune sets aside ₹11.57 lakh disallowance under Section 36(1)(va) for alleged PF/ESI delay, citing conflicting Supreme Court views in Woodland vs Checkmate; matter remanded to CIT(A) for fresh factual and legal adjudication.
The case examined whether delayed filing of Form 10/10B invalidates exemption under section 11(2). The Tribunal held that procedural delays do not defeat substantive claims, directing allowance of exemption.
The Tribunal held that reassessment proceedings were invalid as approval was taken from the wrong authority beyond three years. It ruled that such non-compliance with Section 151(ii) vitiates jurisdiction and renders the notice void.
The Tribunal held that enhancement of income without issuing notice under section 251(2) is invalid. Such action violates principles of natural justice, leading to quashing of enhancement and related penalty directions.
The Tribunal held that unfinished properties classified as work-in-progress cannot be subjected to notional rent under section 23. Since construction was incomplete, the addition was deleted as legally unsustainable.
The Tribunal held that the Assessing Officer cannot examine issues beyond the scope of limited scrutiny without approval. Since total deposits were assessed instead of only demonetization deposits, the addition was invalid and deleted.
The case examined whether compensation paid to exit prior agreements was a sham arrangement. The Tribunal ruled it was a valid business decision that enabled higher sale consideration.
The appeal involved a legal challenge regarding absence of notice under Section 143(2). The Tribunal held that failure to adjudicate this issue required fresh consideration and remanded the matter.
