Actual commencement of charitable activities for regularisation of provisional registration - regular registration u/s 12AB and connected approval u/s 80G(5) denied as time-barred Validity of rejection of the applications for regular registration solely by treating the date of provisional registration as the date of commencement of charitable activities - HELD THAT: - The expression "commencement of its activities" requires examination of the trust's actual charitable activities on the ba... ... ...

BSNL Voluntary Retirement Scheme, 2019 - retrenchment compensation exemption - Capital receipt exemption - Characterisation of compensation received by BSNL employees under the BSNL Voluntary Retirement Scheme, 2019 as retrenchment compensation eligible for exemption under section 10(10B) v/s voluntary-retirement compensation under section 10(10C) - HELD THAT: - The Tribunal found the coordinate decision on identical facts in PRATHIBHA JGADISH UNAWANE [2026 (4) TMI 1888 - ITAT PUNE] squarely ... ... ...

Classification of trust engaged in propagation of Vedas - Approval under section 80G for charitable trust - classifying the appellant-trust as charitable or religious-cum-charitable HELD THAT: - The registration authority assigned no reasons for classifying the Trust as religious-cum-charitable. In view of the legal position enunciated in the decisions of Sole Trustee, Loka Shikshana Trust [1975 (8) TMI 1 - SUPREME COURT] and Maharishi Mahesh Yogi Vedic Vishwavidyalaya vs. State of MP [201... ... ...

Addition u/s 56(2)(vii)(b) - difference between the stated consideration and stamp duty value of a proposed redevelopment flat - Strict construction of deeming provision for land or building Applicability of section 56(2)(vii)(b) to a redevelopment allotment comprising alternative accommodation against surrendered tenancy rights and additional area purchased for consideration, where the proposed building had not been constructed or delivered - HELD THAT: - Section 56(2)(vii)(b) is attracted o... ... ...

Condonation of delay caused by non-service of statutory intimation - Mandatory pre-adjustment notice for return-processing adjustments Condonation of delay caused by non-service of statutory intimation - Condonation of delay in appeal against return-processing adjustments where the assessee remained unaware of the intimation owing to non-availability of accounts and non-service of statutory notice - HELD THAT: - The Tribunal accepted that the assessee came to know of the demand only subsequen... ... ...

Admission of material additional evidence - Fresh adjudication of interconnected SEZ deduction and transfer-pricing adjustment Adjudication of the statutory deduction claimed for the SEZ undertaking and the transfer-pricing adjustment on purchases from the associated enterprise in light of material additional evidence - HELD THAT: - The statutory approvals, licences, contemporaneous agreements and machinery invoices directly bore upon whether the SEZ undertaking was newly established or forme... ... ...

Charitable exemption - benefit to specified persons through excessive payments - Excessive salary and rent paid to specified persons - Application of charitable income for private benefit - HELD THAT: - The Tribunal found that, although the average salary increase was lower, the salary increases granted to two specified persons were substantially higher and excessive having regard to the services rendered. It held that payments out of fees collected from students, when made in this manner ... ... ...

Unexplained money - unsubstantiated source of seized cash - Special-rate taxation of unexplained money - Penalty for unexplained money Unexplained money-unsubstantiated source of seized cash - Special-rate taxation of unexplained money - Addition of seized cash as unexplained money where the claimed business-loan source was unsupported by books or other corroborative evidence, and consequential application of the special rate of tax - HELD THAT: - The Tribunal held that the burden upon the De... ... ...

Maintainability of direct appeal against rectification order - Maintainability of an appeal directly before the Tribunal against an Assessing Officer's rectification order HELD THAT: - The assessee's counsel categorically stated that the intended challenge was to the Assessing Officer's order under section 154 and that no appeal against that order had been filed before the Commissioner (Appeals). An appeal against such order could not be instituted directly before the Tribunal; th... ... ...

Penalty for undisclosed income - identification of specific default u/s 271(1)(c) - Explanation 1 to section 271(1)(c) - bona fide explanation Sustainability of penalty for alleged undisclosed income from mine transactions where the penalty order alternately alleged concealment of income and furnishing of inaccurate particulars - HELD THAT: - Section 271(1)(c) creates distinct defaults which, being penal in character, require strict identification and proof. Non-disclosure of income cannot, w... ... ...

Addition of alleged cash return against recorded tyre sales - Double taxation of income - Addition of alleged unexplained cash stated to have been returned against recorded tyre sales HELD THAT: - The sales had already been recorded in the assessee's books and considered in determining taxable profits. If the sales were regarded as bogus, they were required to be excluded while computing such profits; their retention in the profit and loss account while separately assessing the alleged ca... ... ...

Bogus Share application money - unexplained cash credit - Discharge of onus u/s 68 - Adverse third-party statements - cross-examination - Proof of identity, creditworthiness and genuineness - Adverse third-party statements-cross-examination HELD THAT: - The assessee produced PAN, board resolutions, bank and financial statements, and confirmations from the share applicants. These materials substantiated their identity, availability of funds and the genuineness of the transactions, and were nei... ... ...

Unexplained cash credits - unsecured loans - Burden of proof under section 68 - Proof of identity, creditworthiness and genuineness - Addition for unsecured loans as unexplained cash credits despite documentary evidence of the lenders and banking-channel transactions HELD THAT: - The assessee's burden under section 68 had to be examined with reference to the credits in its own books. Confirmations, PAN details, bank statements, instruction letters and affidavits supported the identity and... ... ...

Surviving limitation for reassessment notices - Revision of a non est reassessment order - Revision for alleged lack of inquiry into exempt long-term capital gains on shares Surviving limitation for reassessment notices - Revision of a non est reassessment order - Validity of revision where the reassessment notice under the new regime was issued beyond the surviving period of limitation - HELD THAT: - Under the legal fiction governing transitional reassessment notices, the balance limitation ... ... ...

Unexplained money u/s 69A - demonetisation-period bank deposits - cash recorded in books of gold and silver ornaments - Double taxation - recorded cash-sale proceeds HELD THAT: - The audited books, cash book, stock and purchase/sales records, sales bills and VAT returns supported the cash-sales explanation, and the Revenue neither identified a defect in those records nor rejected the books under section 145(3) or made an independent verification. Section 69A applies to money not recorded in ... ... ...

Unexplained cash deposits in banking correspondent's settlement account - Penalty for unexplained money pending de novo assessment Unexplained cash deposits in banking correspondent's settlement account - HELD THAT: - The Tribunal accepted that the assessee's inability to track the assessment proceedings was attributable to contact details on the portal not belonging to him. The receipt of commission subject to tax deduction supported the explanation that the account could have be... ... ...

Penalty u/s 271D for cash receipt of immovable-property sale consideration - AO had not recorded satisfaction for initiating penalty proceedings in the assessment order HELD THAT: - The Tribunal held that the binding decisions applicable to it require the Assessing Officer, as the primary authority in the assessment proceedings, to record satisfaction regarding the alleged contravention before initiation of penalty proceedings. The contrary view followed by the Cochin Bench [2025 (3) TMI 1516... ... ...

Section 80IA/80IB deduction for new hydraulic power steering gear undertaking - Depreciation on machinery kept ready for use - Continuity of section 80IA/80IB deduction after initial-year eligibility Section 80IA/80IB deduction for new hydraulic power steering gear undertaking - Integrated and independent manufacturing unit - Commencement of commercial production - Eligibility of the new hydraulic power steering gear undertaking for deduction under sections 80IA/80IB upon its independent manu... ... ...

Prospective application of specified violations for cancellation of trust registration - Specific notice and inquiry for cancellation of trust registration - Benefit to specified persons and cancellation of trust registration Jurisdiction of Principal Commissioner (Central) over transferred trust cases - Jurisdiction of the Principal Commissioner (Central) to cancel trust registration after centralisation of the case - HELD THAT: - Upon transfer of jurisdiction under section 127, jurisdiction... ... ...

Admissibility of electronic evidence in income-tax assessment - Section 65B certification and digital-evidence safeguards - Unexplained cash credits founded on notional and opening-balance entries - Post-search assessment under the reassessment procedure - Revenue and capital expenditure - Disallowance for non-deduction of tax at source Admissibility of electronic evidence - Section 65B certificate - Chain of custody of digital evidence - Reliance on the HP 32 GB pen-drive described as the JS... ... ...