Relying on precedents including rulings of the Delhi High Court, the Tribunal held that extrapolation across years is impermissible. The addition was struck down as being based on assumption rather than evidence.
The Tribunal held that once business receipts are taxed on an estimated basis, separate additions for payments and assets from the same receipts are impermissible. Only a net-profit estimation was sustained, deleting multiple cascading additions.
The tribunal accepted that allotment confers enforceable capital rights capable of transfer. The ruling clarifies that proceeds from such transfers must be assessed under capital gains, not deemed income.
The Tribunal held that disallowance of interest for non-deduction of TDS cannot be automatic when paid to an NBFC. The Assessing Officer must first verify whether the payee has offered the income to tax.
Levy of interest under sections 234B and 234C on income arising from an APA. Interest was deleted as APA income crystallises only on signing, making advance-tax estimation impossible.
The Tribunal reiterated that procedural delays in uploading Form 10B should not defeat substantive tax exemptions available to charitable trusts. Denial of Section 11 relief merely due to late filing was held to be unjustified where charitable activities were undisputed.
The Court held that failure to upload the prescribed form cannot defeat a tax benefit when the option was clearly exercised in the return. Procedural lapses were directed to be regularised under Section 119(2)(b).
The court held that technical difficulties justified condonation of delay in filing the prescribed form for concessional tax. Procedural lapses could not override a valid claim made in the return.
DRAT Allahabad held that initiation of proceeding under SARFAESI Act for the same debt due after rejection of claim under Co-operative Societies Act is not justifiable. Accordingly, the present appeal is allowed.
The Authority held that LED drivers fall under CTH 8504 40 90 since their essential role is electrical energy conversion and regulation, aligning with static converters rather than lighting parts.
