ITAT held that execution and registration of a sale deed completes the transfer for capital gains purposes. Delayed receipt of sale consideration or dishonoured cheques cannot postpone taxability when the registered transfer remains valid.
The ITAT Kolkata held that cash payments made through agents for procuring paddy from farmers were covered by Rule 6DD exceptions. Consequently, the disallowance under Section 40A(3) was deleted.
The petitioner challenged an ex-parte GST assessment order after the appeal period had expired. The High Court remanded the matter for fresh adjudication subject to payment of 25% of the disputed tax and filing of a reply to the show cause notice.
The Court held that although notices were sent to the address available in PAN and passport records, the reassessment order could not stand because the assessee was not given an effective opportunity of hearing. The assessment, demand notices, penalties, and recovery proceedings were set aside.
The ITAT Mumbai held that the assessee had satisfactorily explained the source of Rs. 1.25 crore through bank records, PPF withdrawals, and documented fund movements. Since the transactions were verifiable through banking channels, the addition under Section 69 was deleted.
The ITAT Kolkata found that the assessees share capital remained unchanged throughout the year and no fresh capital was received. As a result, the addition under Section 68 for alleged unexplained share capital was deleted.
ITAT Delhi held that a bad debt deduction cannot be denied once the debt is validly written off in the books of account. The Tribunal ruled that proof of actual irrecoverability was not required in view of CBDT circulars and judicial precedent.
The ITAT Kolkata held that the Assessing Officer could not examine issues beyond the limited scrutiny mandate without following CBDT-prescribed procedures for conversion into complete scrutiny. As a result, the interest disallowance under Section 36(1)(iii) was deleted.
The Tribunal deleted the disallowance of advertisement and publicity expenses after finding that sponsorship of football teams, tournaments, and green movement initiatives was undertaken for business promotion. It held that such expenditure qualified as allowable business expenses.
The Tribunal held that delay in filing appeals was justified where the assessee had shifted to a new PAN and filed returns under it. The matter was remanded to the CIT(A) for fresh consideration.
