The issue was whether protective addition can survive when income is already taxed elsewhere. ITAT held that once income attains finality in another assessee’s case, protective addition cannot be sustained.
The issue was whether deduction under Section 80P is allowed when return is filed late. ITAT held that post-2018 amendment, deduction is barred if return is not filed within the due date under Section 139(1).
The issue was incorrect computation of interest without reducing foreign tax relief. ITAT held that relief under sections 90/90A must be deducted before calculating interest under sections 234A, 234B, and 234C.
The Court found that the appellate authority rejected the appeal solely on delay without examining the reasons provided. It held that such non-consideration renders the order unsustainable and directed fresh adjudication.
The Court emphasized the need for fair opportunity before finalizing tax demands. The petitioner was allowed to respond to the show-cause notice in fresh proceedings.
The issue involved denial of refund on the ground that services were intermediary in nature. The Court held that absence of findings on the agreement and nature of services invalidated the order. The matter was remanded for fresh adjudication with proper analysis.
The issue involved whether fresh scrutiny could be initiated after filing a modified return under Section 170A. The Court held that where assessment is already completed, the AO can only modify income to give effect to reorganisation.
Kerala High Court set aside ITAT orders as mechanical and non-speaking, holding that the Tribunal failed to independently analyze facts, consider submissions, and provide reasoned findings; matter remanded for fresh adjudication.
The Tribunal held that unsigned excel sheets without supporting evidence cannot justify additions. It ruled that absence of corroboration and cross-examination renders such documents unreliable.
The issue was whether indemnity obligations arise only after final appellate confirmation. The Supreme Court held that liability arises once it crystallises, requiring immediate discharge by the indemnifier.
