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.
The Tribunal ruled that a statutory appellate authority cannot pass an ex-parte order after ignoring materials demonstrably available on record. The matter was restored for fresh consideration on all grounds.
The Tribunal reaffirmed that revision is impermissible when the Assessing Officer adopts a reasonable view after due enquiry. Section 263 cannot be invoked merely because the PCIT prefers another line of investigation.
The Tribunal clarified that granting limited broadcast rights without rights to modify or exploit content does not constitute royalty income. The ruling underscores the distinction between copyright transfer and mere broadcast reproduction rights.
The Tribunal reaffirmed that once expenditure is shown to be wholly and exclusively for business, section 37(1) disallowance cannot survive. Suspicion cannot override documentary and commercial reality.
