The Tribunal ruled that appellate authorities must adjudicate each legal and factual ground raised in appeal. A mere remand to the AO without deciding jurisdictional issues violates statutory requirements.
The Tribunal held that Section 68 cannot be invoked unless a sum is found credited in the assessees books. In the absence of any such entry, the addition based on an alleged cash loan was deleted.
The Tribunal held that additional evidence accepted by the appellate authority must be examined by the Assessing Officer. Allowance based only on banking payments and charitable status was found inadequate.
Emphasising substance over form, the ruling clarifies that genuine charitable trusts should not be denied renewal solely on procedural timelines where reasonable cause exists.
The Tribunal held that additions for completed assessment years under section 153A are invalid when no incriminating material is found during search. Reliance on third-party documents and uncorroborated statements was held insufficient to sustain additions.
The Tribunal ruled that the six-month time limit from commencement of activities applies only to newly formed trusts. Long-standing trusts cannot be denied approval solely on this ground.
The issue before the Authority was the classification of evaporators and condensers. It held that heat exchangers imported separately are classifiable as parts, but follow the main unit’s classification when imported together in CKD/SKD condition.
The ruling examined whether a liquid embolic system qualifies as a medicament. It held that since the product acts mechanically by occluding vessels, classification under medicament heading was not applicable.
The ruling clarifies that the power to admit or reject appeals under section 249(4) lies with NFAC/RFAC, not the Appeal Unit. Appeals were restored due to improper exercise of jurisdiction.
The Tribunal held that when corresponding sales are accepted, a full disallowance of alleged bogus purchases is not justified. It restricted the addition to 6% of the purchase value as a reasonable estimate.
