The Tribunal held that ad agencies operate on low margins, and without comparables, an 8% estimate was excessive. Past history was accepted as the best guide, reducing profit estimation to 5% and deleting cash-deposit addition as double counting.
Summary: The Supreme Court held that a sub-vendor cannot force arbitration against a principal employer without contractual privity. BCL’s claim failed as it lacked genuine intent to be bound by HPCL’s agreement.
Tribunal held that a notice issued by JAO under Section 148 is invalid, emphasizing that only FAO-issued notices comply with faceless reassessment rules. Revenue may seek revival if Supreme Court changes legal position.
Tribunal ruled Section 54F exemption is not available when the assessee owns multiple independent residential units, each with a separate kitchen. Deduction on the JDA property was disallowed.
ITAT Kolkata ruled that WhatsApp chats without corroboration cannot be treated as unexplained income under Section 69A. All additions based solely on chats were deleted, emphasizing the need for tangible evidence.
ITAT held that mass same-day approval without reviewing records violated Section 153D. The ruling confirms that mechanical approvals invalidate 153A assessments.
ITAT ruled that reopening assessment under Section 147 is invalid if the filed return is ignored. The case was remitted for fresh consideration after allowing the assessee to substantiate claims under Section 54F.
The Tribunal held that reopening under Section 147 was legally sound and unaffected by arguments based on 153C or Notification 18/2022. Still, it directed a full rehearing because the appellate authority issued non-speaking orders without examining the merits.
ITAT Hyderabad rules that gross sale proceeds of capital assets cannot be treated as taxable income without allowing cost of acquisition. Tribunal orders reassessment to compute correct capital gains, despite assessee’s non-compliance.
ITAT held that an appeal delayed by almost six years must not be dismissed outright without examining genuine hardships. Medical evidence of the assessee’s child justified potential condonation of delay. The case highlights the balance between limitation and natural justice.
