ITAT held that most jewellery seized during a search could be accounted for from declared drawings and past income, reducing addition to ₹72.45 lakh. Ruling emphasizes that unexplained investment must be proven in relevant assessment year.
ITAT held that additions under section 153A cannot be made if no incriminating material is found at the assessee’s premises; third-party documents should be invoked via section 153C.
ITAT held that post-29.03.2022, notices must be issued faceless; issuance by JAO violated law, invalidating the reopening and assessment.
The tribunal ruled that reassessment notices issued after April 2021 for AY 2015-16 are invalid, as they fall outside TOLA provisions and are time-barred.
The Tribunal held that reopening based solely on an NMS alert and without examining DTAA-exempt interest income violated Section 115A(5). The ruling confirms that non-residents cannot be reassessed when TDS-deducted income does not escape tax.
ITAT held that managing multiple bank accounts justified salary expenses claimed under Section 57(iii). The ruling restores full deduction and reinforces that recurring administrative costs can be allowable against interest income.
Ramchandra Ingot India Private Limited Vs DCIT (ITAT Kolkata) Investments Accepted in Earlier Scrutiny Cannot Be Treated as Bogus u/s 68 on Sale—5% Profit Estimation by CIT(A) Deleted; The assessee and the Revenue filed twelve cross-appeals for AYs 2016-17 to 2021-22 against separate orders of CIT(A)-27, Kolkata. The central dispute arose from additions made u/s […]
ITAT held that subscription fees received by a global e-commerce platform from Indian customers are not taxable as Fee for Technical Services (FTS). Standard automated digital facilities without human intervention cannot be treated as FTS under Section 9(1)(vii) and India–Singapore DTAA.
Tribunal highlighted that short-term and long-term capital gains from share sales, under sections 111A and 10(38), were properly taxed, reflecting assessee’s investment intent.
ITAT Delhi permits set-off of brought forward long-term and current year short-term capital losses against long-term capital gains, overruling CPC and CIT(A).
