Karnataka HC confirms that compensation for land acquired under National Highways Act after 01.01.2014 is fully exempt under Section 96 of RFCTLARR Act, preventing any TDS or income tax deduction.
Court held that exemption under Section 10(23BBA) applies only to bodies constituted under State enactments, not to temples or deities whose income is separately taxable. Temples must seek relief under Sections 11–12 instead.
Tribunal held that denying opportunity to submit evidence amounts to potential miscarriage of justice. CIT(A) directed to reconsider income addition after evaluating all documents.
ITAT held that appeals filed with incorrect jurisdiction cannot be heard. All four appeals dismissed, but assessee allowed to refile before correct bench.
ITAT ruled that Section 201 proceedings initiated beyond four years are legally untenable. Since the 201(1) order for AY 2016-17 was issued after the limitation period, the entire TDS demand was deleted. Tribunal held that date of knowledge is irrelevant for limitation.
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.
