The issue was whether late filing of Form 67 bars foreign tax credit under DTAA. ITAT held that FTC is a substantive right under section 90 and cannot be denied for a procedural delay.
The AO relied on human probability, abnormal price movement and third-party material. ITAT held that without direct evidence against the assessee, LTCG cannot be branded sham.
The issue was whether dividend income loses s.10(34) exemption due to violation of s.11(5). ITAT held that income excluded under Chapter III never enters s.11 computation, so dividend remains exempt.
The assessee sought to contest an EPF/ESI disallowance arising only from CPC processing. ITAT ruled that issues from 143(1) must be challenged independently, not through a 143(3) appeal.
The assessee explained that income and TDS were recognized in different financial years. ITAT restored the matter for limited verification and barred automatic taxation.
The Tribunal ruled that cash deposited from recorded demonetisation-period sales cannot be treated as unexplained when books and VAT turnover are accepted. Suspicion without evidence cannot justify section 69A additions.
The issue was whether filing ITR-7 instead of ITR-5 justified blanket disallowance of expenses. ITAT held that wrong ITR selection is a procedural lapse and cannot wipe out genuine expenditure.
The AO passed a rectification order while the core section 50C addition was pending fresh adjudication. ITAT ruled that such parallel adjudication leads to inconsistency and must be avoided.
ITAT Delhi held that Section 148 notices issued with approval from an incorrect authority are invalid. Reassessment orders for AYs 2016-17 and 2017-18 were quashed.
The issue was whether bogus purchases disallowed under section 37(1) must be reclassified as unexplained expenditure under section 69C. ITAT held that where the source of expenditure is known, section 69C cannot be mechanically invoked.
