The ITAT Delhi deleted the TDS demand under Section 194-I, confirming that the obligation to deduct tax on lease rent paid to NOIDA Authority applies prospectively from 16.02.2017. Following Supreme Court precedents, the Tribunal ruled the real estate firm was not an assessee-in-default for payments made in FY 2011-12.
Delhi HC ruled that date of electronic upload of DRP directions on ITBA is date of receipt under Section 144C(13). AO’s final order passed a day late was held invalid, reaffirming that physical delivery is irrelevant once uploaded.
The ITAT Kolkata restored Section 12A registration and Section 11 exemption to the Chamber of Commerce, holding that its objects and activities are charitable in nature, similar to the Indian Chamber of Commerce. The Tribunal applied the rule of consistency, noting the Chamber’s registration was already granted for subsequent assessment years.
The ITAT Kolkata ruled that no disallowance under Section 14A read with Rule 8D can be made if the taxpayer did not earn any exempt income during the relevant financial year. The Tribunal fully allowed the appeal, reiterating the established legal position against mechanical disallowance when there is no dividend or tax-free income.
The ITAT Delhi dismissed the Revenue’s appeal, confirming that the reassessment proceedings initiated in the name of the erstwhile amalgamating company were void ab initio. The Tribunal ruled that since the amalgamation was duly communicated to the Assessing Officer before the assessment, the notice issued to the non-existent entity was invalid in law.
The Delhi High Court dismissed the Revenue’s appeal, affirming that a prior approval for search assessments under Section 153D must involve the superior authority’s conscious application of mind. The Court held that approvals granted mechanically or through a single omnibus letter for numerous assessments are invalid, thereby quashing the assessment.
Court held that authorities cannot block Input Tax Credit accrued after the date of action, directing restoration of ₹1.43 crore to the taxpayer while upholding blockage of earlier credit.
The ITAT Pune condoned a 100-day delay in filing the tax appeal, citing reasonable cause due to the taxpayer’s reliance on professional advice and relocation. Adopting a justice-oriented approach, the Tribunal allowed the appeal to be heard on its merits, reinforcing the principle that substantive justice prevails over procedural lapses.
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The ITAT struck down the additions, observing that the AO’s jurisdiction was potentially vitiated by a mechanical, consolidated approval for reopening, and the additions themselves relied solely on an uncorroborated statement and rough papers. The ruling confirms that unverified, rough documents lack sufficient evidentiary value to sustain income additions.
