The ITAT found the AO’s valuation incorrect, emphasizing that FMV must be determined on the date of transfer, leading to the restoration of the long-term capital loss for the Assessee.
The Tribunal directed AO to compute Section 14A disallowance only for investments generating exempt income, following Rule 8D. The decision reinforces the need for precise calculation of disallowances against exempt income.
ITAT quashed the reassessments, agreeing with prior ruling that combined approval under section 148B for multiple assessees violates legal requirements.
ITAT Mumbai condoned 75-day delay in filing appeal, recognizing assessee’s illiteracy and reliance on tax consultant, allowing fresh adjudication on merits.
The Tribunal set aside the ex parte dismissal of the AY 2018-19 appeal, restoring the matter to CIT(A) for merits-based hearing. The assessee was allowed to present evidence regarding ₹3.74 crore unexplained investment and estimated profits.
AO treated ₹13 lakh cash deposits as unexplained, but ITAT found all deposits supported by cash book and bank self-cheques. Entire addition under section 68 was deleted.
ITAT held reassessment invalid where AO acted on belated return without issuing mandatory 143(2) notice. Entire reassessment under sections 144/147 was quashed despite late filing of return.
The Tribunal upheld CIT(A)’s deletion of ₹2.81 crore transfer pricing adjustment, ruling that selected comparables were functionally and financially dissimilar. PSM was maintained as the Most Appropriate Method, ensuring fair benchmarking of international transactions.
Tribunal found the appellate order non-speaking, failing to consider multiple submissions including 54F claims and compensation deductions. The matter is remanded for comprehensive review and proper opportunity of hearing.
CIT(A) wrongly rejected the assessee’s rectification petition under section 154 despite portal evidence. ITAT restored the appeal for fresh adjudication with full opportunity to submit evidence.
