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The Tribunal held that entire purchases cannot be disallowed when corresponding sales are accepted. It upheld restriction of addition to profit element, preventing unrealistic income computation.
The Tribunal held that additions cannot be made merely on survey statements without rejecting books of account or providing proper opportunity. It deleted the addition for alleged underreported profit, emphasizing adherence to due process.
The Court condoned a 179-day delay and admitted the appeal on questions involving Section 263. It will examine whether the Tribunal erred in quashing revisionary action.
The Tribunal held that a minor delay in filing Form 10-IC should not deny concessional tax benefits. It emphasized that substantive compliance prevails over procedural defects.
The Tribunal held that no double deduction was claimed as the provision was already added back in computation. The addition was deleted for being based on incorrect facts.
The Tribunal found that additions were made without considering joint ownership and without referring valuation to the DVO. The matter was sent back for fresh adjudication with proper verification.
The Tribunal held that delay in filing Form 10-IC does not invalidate the option exercised under Section 115BAA if declared in the return. It ruled that the requirement is procedural, not mandatory. The decision ensures substantive tax benefits are not denied due to technical lapses
Tribunal directed allocation of common head-office expenses (and common income) to eligible industrial undertakings when computing deductions under sections 10B and 80-IB, following prior coordinate-bench rulings; AO must apply the earlier directions on remand. Key takeaway: common corporate overheads and income were to be apportioned to units for deduction-computation as previously directed.
The tribunal set aside the assessment after finding that faceless assessment proceedings were initiated before the scheme was formally notified, rendering the assumption of jurisdiction invalid.
The Tribunal upheld the disallowance of HRA exemption under Section 10(13A) as the assessee failed to submit any supporting documents for rent payments. In the absence of evidence, the claim of ₹1,08,000 was rightly disallowed.
