ITAT Bangalore upheld the CIT(A)’s decision that reassessment proceedings for AY 2015-16 were barred by limitation. The Tribunal found no error in relying on the Supreme Court’s ruling on reassessment timelines.
The ITAT held that compensation paid to terminate a land sale agreement was a business expenditure incurred for commercial reasons. The amount could not be treated as part of closing stock and was allowable under Section 37.
The Delhi High Court upheld deletion of additions after authorities under the Black Money Act concluded that the assessee was not the beneficial owner of the foreign assets. The Court held that a protective assessment could not survive on those facts.
The ITAT held that reassessment proceedings were invalid because the recorded reasons for reopening were undated and failed to establish compliance with Section 148 requirements. The assessment was quashed as a jurisdictional defect.
The Bombay High Court held that a 13-day delay in filing Form 10-IC should be condoned where eligibility for Section 115BAA was undisputed. The Court ruled that procedural requirements cannot override substantive statutory benefits.
The Supreme Court dismissed the Revenue’s SLP by following its earlier decision in connected matters. The dispute relating to advance sale of room nights and Holiday Scheme Surrender Value remained governed by settled precedent.
The Court found that the tax treatment of advance sale of room nights had already been addressed in earlier decisions concerning the same assessee. The Revenue failed to show any reason for a different outcome.
The ITAT held that transfer pricing adjustment was not justified where the foreign LLC’s income was already offered to tax in India by the assessee. The Tribunal deleted the TP addition, finding no profit shifting or tax erosion.
ITAT Kolkata held that TDS under Section 194C was not required on materials purchased for installation work. The disallowance under Section 40(a)(ia) was reduced substantially after excluding the material component.
ITAT Delhi held that a 22-day delay in filing Form 10-IC could not deprive an eligible company of the concessional tax rate under Section 115BAA. The Tribunal treated the delay as procedural and directed recomputation at the lower rate.
