In a trading business case, the ITAT confirmed that income estimation must be fair and reasonable. Due to the lack of cogent material from the Department to support an 8% NP rate, the Tribunal intervened to fix the rate at 4%.
Delhi ITAT rules that disallowance of Section 80M deduction and GST refund mismatches are debatable issues, falling outside limited jurisdiction of Section 143(1). Intimation against Coforge Ltd. quashed for being ultra vires and violating natural justice.
Delhi ITAT upholds the ₹50 Lakh bogus sale addition against a jeweller, finding no proof of bullion transport and confirming the buyer was an entry operator.
Delhi ITAT sustained a Rs.14.69 Cr unexplained loan addition under Section 68 against Alvin Reality, ruling that companies with less than Rs.2,000 in income and minimal reserves cannot be deemed creditworthy to advance multi-crore loans.
Following SC’s E-Funds ruling, Delhi ITAT confirmed Concentrix US has no PE in India. The Tribunal also held that IPLC/link charges are non-taxable reimbursements, not ‘royalty’ under Article 12 of the India-US DTAA.
The ITAT Delhi ruled that Section 68 (unexplained cash credits) cannot be invoked against journal entry adjustments where no cash or equivalent funds flowed into the assessee’s account. The ₹10.51 Cr addition was deleted.
Delhi ITAT confirms that an AO cannot disallow purchases of Rs.3.82 Cr as bogus (Adventure Resorts And Cruises Pvt. Ltd.) without rejecting the books of accounts under Section 145.
ITAT Delhi quashes the assessment for Carissa Investment Pvt. Ltd., holding that an AO who ignores a previously accepted correct address forfeits the presumption of valid service.
The ITAT Delhi sets aside a Rs.1.03 Cr addition to a trader’s income, ruling that the creditor balance cannot be taxed under Section 68 when the AO accepts the substantial volume of sales and corresponding purchases.
ITAT Delhi allows NRI’s appeal in Chirag Kirpal Vs ACIT, ruling that the Jurisdictional AO (JAO) lacks the power to issue a Section 148 notice after the Faceless Reassessment Scheme (s.151A) took effect.
