ITAT held that the assessee discharged the burden of proving identity, creditworthiness, and genuineness. Addition was deleted as AO relied only on suspicion without evidence.
The Tribunal clarified that possession is not a mandatory condition for claiming Section 54 exemption. It held that investment within the prescribed timeline satisfies the legal requirement.
The Supreme Court held that employer-provided group insurance benefits cannot be deducted from motor accident compensation as they arise from an independent contractual relationship. It ruled that such benefits do not have a direct nexus with the accident and cannot reduce statutory compensation.
The ITAT held that revision under Section 263 cannot be invoked where the Assessing Officer has conducted detailed inquiries and adopted a plausible view. The Tribunal ruled that a mere change of opinion by the PCIT does not render the assessment order erroneous or prejudicial.
The Tribunal held that entire purchases cannot be disallowed when corresponding sales are accepted. It upheld restriction of addition to profit element, preventing unrealistic income computation.
The Court clarified that recovery actions must be confined to the assessee liable for tax. Attaching a director’s personal account without evidence of liability was held unlawful. The judgment underscores limits on recovery powers.
The issue involved expiring tenures of tribunal members and lack of replacement mechanisms. The Supreme Court permitted a uniform extension framework up to September 2026. The decision aims to maintain operational tribunals pending legislative reform.
The Tribunal upheld the disallowance of HRA exemption under Section 10(13A) as the assessee failed to submit any supporting documents for rent payments. In the absence of evidence, the claim of ₹1,08,000 was rightly disallowed.
The Madras High Court held that penalty under Section 271(1)(c) cannot be imposed where a DTAA claim was made based on a bona fide interpretation of law and full disclosure of income.
The High Court noted that large penalties were imposed on corporate entities while the individual accused faced only a limited penalty, making the restriction on travel unjustified.
