The Tribunal rejected the Revenue’s argument that taxpayers must seek AO determination under Section 195(2) in all cases. It held that such obligation arises only when income is chargeable to tax in India. This ruling reduces procedural burden where taxability itself is absent.
Interest on customs refund was not automatic and depends on whether there was delay in processing attributable to the department, while granting relief in cases where reassessment and refund were delayed and denying it where refunds were issued within the statutory period.
The Court found that the petitioner was not given adequate time or opportunity to respond. It ruled that rejection without following procedural safeguards is invalid. The decision reinforces adherence to due process.
The Court granted bail noting that allegations were primarily based on documentary evidence and investigation was largely complete. It held that further custodial interrogation was not necessary.
The Court set aside the GST order as it was issued before the date fixed for hearing, denying the petitioner an opportunity to respond. The ruling highlights the importance of adhering to procedural timelines.
The issue was whether CSR expenditure disallowed under Section 37(1) can still qualify under Section 80G. The Tribunal held that both provisions operate independently, allowing deduction if statutory conditions are met.
The case addressed disallowance of interest under Section 57 for lack of nexus. The Tribunal allowed the deduction, holding that consistency in earlier years and increased investments justified the claim.
The issue involved eligibility of interest from employee loans. The tribunal ruled that such income is not directly linked to core credit activity. Therefore, it is taxable as income from other sources
The issue involved taxability of interest earned from statutory deposits. The tribunal held that such income is attributable to business activities and qualifies for deduction. This highlights the importance of statutory obligations in determining tax treatment.
The Supreme Court dismissed the Revenue’s appeal citing unexplained delay and no merit in challenging the High Court ruling. The High Court had quashed reassessment for lack of facts specific to relevant assessment years.
