Where ITAT directed inclusion of Cepha Imaging Pvt. Ltd. as a comparable solely on the basis that it satisfied the export turnover filter without examining its functional comparability with assessee, and further directed inclusion of CG Vak Software & Exports Ltd.
Addition of ₹11.14 crore on account of alleged bogus purchases could not be sustained without first verifying the assessee’s claim that purchases worth approximately ₹11.07 crore had been reversed in its books and were never claimed as a deduction while computing taxable income.
Fee reduction of ₹50,000 for the Interim Resolution Professional (IRP) ordered by NCLT was reasonable, given that the IRP’s role was restricted by an interim stay on the constitution of the Committee of Creditors (CoC) between February 28 and September 1, 2023.
Periodic or annual fees paid to a sports governing body to sustain annual league participation rights qualify as operational revenue expenses, not capital investments. Hospitality, travel, and boarding expenses incurred on celebrities and VIPs were fully deductible if they were used strategically to amplify brand visibility, ticket distribution, and corporate sponsorships.
Assessments arising from searches conducted after 01.04.2021 must strictly comply with the reassessment framework under sections 147 and 148. Failure to adhere to statutory jurisdictional requirements, including mandatory approvals and satisfaction for use of third-party material, rendered the entire assessment void.
Tribunal held that the differential amount between the levy price of sugar and the concessional price at which it was sold by a co-operative factory to its members and non-members constitutes an unallowable appropriation of profit to be added to business income, or a valid business practice could not be decided without examining the factual parameters mandated by the Supreme Court in Krishna Sahakari Karkhana Ltd.
When an educational society was found to be substantially engaged in genuine charitable activities, its exemption could not be denied under Section 13(1)(b) simply because a few specific expenditures happened to benefit individuals from a particular religious community.
For deduction on carbon credits, Section 80-IA deduction on the sale of CERs must be allowed; gains from the prepayment of deferred sales tax constituted capital receipts, meaning Commissioner’s relief required no interference.
AO observed an imbalance: the investor companies brought in massive investments but received a minimal percentage of equity, while the promoters retained overwhelming majority control despite investing a lower proportionate amount (Rs. 45 crores)
Eempt income, which were disallowed under Section 14A could not be automatically added back to compute the book profit for Minimum Alternate Tax (MAT) under Section 115JB without pinpointing real, actual expenditures recorded in the books of accounts by tax authorities that possess a direct nexus with the tax-free earnings.
