The Tribunal held that the ₹2.5 Cr flat investment was fully explained through agreement details and a DHFL housing loan, leaving no basis for an addition. Penalty u/s 271(1)(c) was remanded for fresh examination since the foundation for concealment no longer survived.
The assessee’s plea that delayed PF/ESI deduction was a debatable issue was rejected because Checkmate had settled the law retrospectively. The key takeaway is that once the Supreme Court clarifies the law, CPC may apply it through 143(1)(a) adjustments based on audit disclosures.
Covers the Tribunal’s ruling upholding most TPO-selected comparables while excluding product-owning entities, clarifying how functional similarity drives benchmarking in software distribution.
The Tribunal found no evidence of concealment since the assessee had transparently disclosed impairment, CENVAT credit treatment, and revenue recognition. It ruled that Section 271(1)(c) cannot be invoked merely because the AO made additions.
ITAT ruled that the CIT(A) wrongly treated the DVO’s report as binding and failed to independently scrutinize comparables, methodology, and objections. Key takeaway: the first appellate authority must evaluate the DVO’s report on merits and issue a speaking order.
The tribunal held that the State Electricity Board consumer tariff of ₹6.62/unit was the valid internal CUP for captive power transfer. Rejecting comparisons with generating companies, it ruled that no downward adjustment was required. The key takeaway is that actual SEB purchase rates can reliably determine market value for 80IA claims.
Tribunal held that the AO had validly recorded dissatisfaction with the assessee’s 14A working and rightly invoked Rule 8D, confirming interest disallowance while remanding only the investment-averaging computation for Vireet-based recalculation.
This case addressed the scope of judicial interference under the Arbitration Act regarding the interest awarded in a commercial dispute. The Court found no perversity in the Arbitrator’s decision to award the contractual 24% rate, rejecting the borrower’s claims under the outdated Usurious Loans Act, 1918. The ruling emphasizes that the Arbitration Act framework overrides State usury laws for NBFC lending and bars courts from reopening contractual rates.
The PCIT held the AO’s assessment under section 143(3) as erroneous and prejudicial to Revenue, directing fresh verification of various deductions. The assessee argued all claims were correctly examined, questioning the jurisdiction of section 263.
The Tribunal found that the CIT(A) did not examine or reason with respect to substantial documentary evidence submitted by the assessee. The case was remanded to the AO for fresh adjudication to ensure proper evaluation of bank statements, ledger entries, and receipts.
