ITAT Delhi held that a single Section 153D approval for multiple assessees and years is impermissible, rendering all 153A and 153C assessments void ab initio.
ITAT Delhi allowed travelling and visa expenses paid by assessee’s sons as wholly & exclusively for business purposes in overseas education consultancy. The Tribunal emphasized that procedural delay of 5 days should not defeat substantive justice, partly allowing the appeal.
ITAT Kolkata condoned an extraordinary delay in filing appeals, emphasizing that genuine and unavoidable reasons justify late filing, allowing the appeals to proceed for adjudication.
ITAT ruled that a Section 50C addition cannot stand without a DVO reference where market value is disputed. Matter remanded for fresh valuation and reconsideration.
The Court upheld the deletion of penalty under the Black Money Act after finding the wife was only a joint holder and the husband had fully disclosed the foreign asset. The ruling notes no substantial question of law arose.
Court ruled that FEMA summons issued under Section 37 operate within a civil-procedural framework and are not subject to gender-based safeguards under Section 160 CrPC. The key takeaway is that a woman cannot claim exemption from personal appearance in FEMA inquiries.
Registration under section 80G was rejected due to a clause suggesting financial assistance abroad. Ruling: ITAT held application of income occurs in India. Key takeaway: Mere mention of foreign studies cannot block 80G registration.
The Tribunal held that Section 69 additions based solely on pen-drive data and an employee’s statement from a third-party search could not be sustained. No corroboration or confrontation to the assessee was provided. The ruling confirms that unsupported electronic data cannot create taxable on-money additions.
The Tribunal held that Section 44AD could not be applied to a goods carriage business excluded under Section 44AE and restored the matter for fresh examination. The AO must verify conditions under Section 44AE and recompute income accordingly.
ITAT Bangalore allowed deduction of ₹55.4 crore ESOP expenses under section 37, holding it as employee compensation cost. ESOP costs may be deductible even if cross-charged from parent company.
