ITAT Mumbai held that disallowance of interest expenditure under Rule 8D(2)(ii) of the Income Tax Rules is not sustainable since the assessee’s own interest-free funds were substantially higher than the investment. Accordingly, appeal of revenue dismissed and order of CIT(A) upheld.
Section 7 application was initiated fraudulently and with malicious intent, in collusion between the Financial Creditor and the Corporate Debtor, for purposes other than genuine insolvency resolution.
Project cost or turnover could constitute a relevant and permissible yardstick for quantification of environmental compensation, provided the determination was reasoned, proportionate and bears a rational nexus to the scale of violations.
The ruling addressed whether a delayed application could survive after statutory change. The Tribunal directed fresh consideration by applying the liberalized timeline introduced by Finance Act, 2024.
ITAT Chennai held that merely opting for Vivad-Se-Vishwas does not end an appeal unless settlement is completed; dismissal by assumption was invalid and appeal was restored for merits adjudication.
The High Court held that limitation for filing a GST appeal must be computed after disposal of a rectification application. Rejection of the appeal without examining this aspect was found invalid.
Addition under Section 68 cannot be sustained merely due to high share premium when investors are identifiable, traceable, and supported by audited financial records.
ITAT Chennai held that once delay in filing return is condoned under section 119(2)(b), CPCs denial of deduction under section 80P collapses and relief must be granted.
The tribunal held that a purchase cannot be treated as bogus solely based on third-party allegations. Without independent verification by the Assessing Officer, the disallowance was held unsustainable.
The case examined whether multiple agricultural properties were joint family assets or self-acquisitions. The Supreme Court upheld findings that ancestral income existed, shifting the burden to prove self-acquisition, which failed.
