The ITAT upheld deletion of a major share premium addition after finding that all investors complied with notices under Section 133(6) and furnished requisite documents. The ruling reiterates that once the three ingredients of Section 68 are satisfied, the burden shifts to the Revenue.
The Tribunal held that estimating closing stock without rejecting books or identifying defects is unsustainable. Mere assumptions of revenue leakage cannot justify additions.
ITAT Mumbai held that condoning a delay in filing an appeal does not replace the right to present submissions on merits and remanded the case for fresh adjudication.
The Tribunal held that amalgamation approved by the High Court cannot be treated as a sham or business reconstruction. Deduction under Section 80IC was upheld as the eligible unit continued unchanged.
The Tribunal held that Section 69A applies only to money not recorded in books of account. Additions based on duly recorded, bank-routed transactions were found unsustainable.
ITAT Delhi directed that a trust lacking 12A registration cannot be taxed on gross receipts; only surplus income applied outside charitable purposes is taxable.
LL Global Inc. Vs ACIT (ITAT Delhi) ₹50 Lakh Threshold Is Mandatory: ITAT Delhi Quashes Reassessment of Foreign Company as Time-Barred Delhi ITAT (Bench ‘D’) quashed the reassessment proceedings initiated u/s 147 r.w.s. 148, holding them to be barred by limitation under the amended law. The Tribunal noted that the notices u/s 148 were issued […]
ITAT Delhi ruled that CIT(E) cannot evaluate the merit of charitable activities when granting 12AB/80G registration, restoring the trust’s exemptions. Procedural overreach by tax authorities cannot deny valid registration.
ITAT Delhi ruled that a sub-broker’s turnover includes only brokerage income, not total client transactions, and deleted ₹1.5 lakh penalty under Section 271B.
ITAT allowed condonation of a 321-day delay in appeal filing, emphasizing procedural fairness when assessment orders are delivered electronically.