The Tribunal held that the Assessing Officer cannot apply FMV for capital gains and book value for business income on the same converted asset. Section 45(2) mandates consistent valuation to prevent artificial inflation of taxable income.
The Tribunal held that royalty is includible in transaction value only for the normal period, while other statutory levies are excluded. Extended limitation, penalty, and interest were set aside due to absence of intent to evade duty.
Since the primary object was the advancement of an object of general public utility without a profit motive, the activities did not constitute trade, commerce, or business. Therefore, the restrictions in the proviso to Section 2(15) were not applicable and assessee was held entitled to the exemption under Section 11.
The Appellate Authority clarified that refund-related queries are not among the issues specified for advance rulings under the CGST Act. The ruling underscores the limited scope of advance ruling jurisdiction.
The Tribunal upheld disallowance of political donation deductions where the assessee failed to prove genuineness and the transactions were linked to suspected accommodation entries. The ruling reinforces the burden on taxpayers to substantiate claims under section 80GGC with credible evidence.
The Tribunal remanded the case after finding that the addition was made solely on Investigation Wing inputs without proper verification or disclosure of details to the taxpayer.
The ruling clarified that increased expenditure in one year, by itself, does not permit partial disallowance. The Assessing Officer must demonstrate lack of business purpose or genuineness.
The High Court held that quick repayment alone cannot establish a paper transaction when identity, creditworthiness, and genuineness are proved through records.
The Tribunal held that adverse regulatory findings alone cannot justify tax additions when client code modification trades are already recorded in the books and profits are disclosed.
The Appellate Tribunal held that delay can be condoned without a formal application if sufficient cause is evident from the record, allowing insolvency proceedings to continue on merits.
