The ITAT ruled that section 151 approval must strictly correspond to the recorded reasons for reopening. Any factual inconsistency reflects non-application of mind and collapses the reassessment at inception.
The Tribunal held that no disallowance under Section 14A is warranted when exempt dividend arises incidentally from shares held as stock-in-trade in banking business. Applying Supreme Court precedents, it deleted the entire sustained disallowance, reaffirming that such income does not trigger Section 14A.
The AO taxed entire bank credits despite accepting the assessee as an entry operator. ITAT ruled that fund rotations cannot be treated as unexplained once the nature of business is admitted.
ITAT ruled that an allotment letter constitutes a valid agreement for section 56(2)(x) where consideration and binding terms are recorded. Stamp duty value on the allotment date, not the delayed registration date, must be applied.
ITAT remanded a ₹2.90 crore s.54F deduction case, allowing the assessee to furnish complete documentation and have the claim re-examined on merit.
ITAT acknowledged that ECB interest was fixed and consistently accepted in earlier years but adopted a marginally revised rate after the assessee’s voluntary settlement to close the dispute.
The Tribunal ruled that section 263 cannot be invoked merely because no addition was made during reassessment. When the AO conducts proper enquiries and accepts the explanation, revision fails for lack of error and prejudice.
The Tribunal rejected the Revenue’s claim that breed development expenses are capital merely due to long-term benefits. What matters is business purpose and operational nexus, not incidental endurance.
The issue concerned excess interest deduction claimed by inflating EBITDA through Ind-AS fair-value adjustments. ITAT held that the AO made no enquiry on this critical computation, making the assessment erroneous.
The issue was whether a later retraction could override an admission made during search proceedings. ITAT held that a clear statement under section 132(4) has high evidentiary value and cannot be nullified without strong proof.
