The ITAT Ahmedabad held that ad hoc disallowance of business expenditure cannot be sustained when audited books are accepted and no specific defects or bogus expenses are identified. The Tribunal deleted the entire 10% estimated addition.
Delhi ITAT held that an assessment initiated through Section 153C proceedings could not be completed under Section 143(3). The Tribunal ruled that the resulting jurisdictional defect rendered the assessment invalid.
The Delhi ITAT held that rejection of books under Section 145(3) was unjustified where the tax authorities failed to identify specific discrepancies. The Tribunal deleted the profit estimation-based addition and emphasized the need for concrete defects before rejecting accounts.
The Tribunal ruled that vague information and an excel sheet prepared by the Investigation Wing could not satisfy the statutory requirement of reason to believe under Section 147. It emphasized that reassessment powers cannot be exercised on mere suspicion. The notice issued under Section 148 was therefore quashed.
ITAT Mumbai noted that the excel sheets relied upon by the Revenue had not been established in accordance with legal requirements governing electronic evidence. Since the material lacked evidentiary support, the addition for Alleged On-Money Payment could not survive.
ITAT Mumbai held that an addition based solely on a builder’s statement could not survive without evidence directly linking the assessee to the alleged cash payment. The ₹4 lakh addition was deleted for lack of corroboration.
The ITAT Delhi held that reassessment under Section 147 was invalid because the Assessing Officer merely relied on an investigation report without applying independent mind. The Tribunal ruled that such material did not establish a valid reason to believe that income had escaped assessment.
ITAT Delhi held that television channel and content owner companies could not be compared with a content distribution business. The Tribunal directed exclusion of such entities from the transfer pricing comparables list.
ITAT Mumbai held that distribution fees paid to associated enterprises could not be treated as royalty. The Tribunal followed earlier decisions and directed fresh transfer pricing analysis based on proper comparables.
The Tribunal found that the assessee had produced complete evidence proving allotment, holding, dematerialization, and sale of shares through the BSE. Since the Revenue failed to disprove these documents or establish any manipulation by the assessee, the LTCG exemption could not be denied. The additions under Section 68 and for alleged commission were deleted.
