The Tribunal held that consultancy payments for architectural services were not FTS since no technical knowledge was made available. Disallowance under Section 40(a)(i) was deleted.
The issue was whether utilisation of earlier accumulated income qualifies for fresh exemption. The Tribunal held it amounts to double deduction as exemption was already claimed earlier.
The Court examined whether an FIR without prior sanction under GST law is sustainable. It allowed investigation but restrained arrest and barred filing of the charge sheet pending further hearing.
The issue was mis-declaration of quantity, value, and classification of imported goods. The Tribunal upheld reassessment and duty demand as the importer admitted discrepancies.
The issue was whether purchases could be treated as bogus based on investigation reports. ITAT held that when documentary evidence and asset existence are proven, additions cannot be sustained.
The Court held that rejecting condonation solely because the assessment year was not mentioned in the circular is unjustified. It ruled that beneficial circulars must be applied liberally to address genuine hardship.
The Tribunal held that purchases cannot be treated as bogus when supported by invoices, bank payments, and GST records. It ruled that absence of adverse evidence makes such additions unsustainable.
The Court held that a 21-month delay in recording the satisfaction note violates the requirement of immediacy. It ruled that such delay renders proceedings time-barred and invalid.
ITAT held that once an assessee adopts a prescribed valuation method under Rule 11UA, the AO cannot change or substitute it. The ruling reinforces taxpayer autonomy in selecting valuation approaches.
Reassessment proceedings was invalid for a notice issued beyond three years without the sanction of the prescribed higher authority as prior approval must mandatorily be obtained from the authorities specified under Section 151(ii) and approval by the Principal Commissioner was not valid in such cases.
