The Court found that the tax treatment of advance sale of room nights had already been addressed in earlier decisions concerning the same assessee. The Revenue failed to show any reason for a different outcome.
The ITAT held that transfer pricing adjustment was not justified where the foreign LLC’s income was already offered to tax in India by the assessee. The Tribunal deleted the TP addition, finding no profit shifting or tax erosion.
ITAT Kolkata held that TDS under Section 194C was not required on materials purchased for installation work. The disallowance under Section 40(a)(ia) was reduced substantially after excluding the material component.
ITAT Delhi held that a 22-day delay in filing Form 10-IC could not deprive an eligible company of the concessional tax rate under Section 115BAA. The Tribunal treated the delay as procedural and directed recomputation at the lower rate.
The Uttarakhand High Court set aside a GST assessment order after finding that the personal hearing was scheduled before the last date for filing a reply. The Court held that such a hearing was illusory and remitted the matter for fresh adjudication.
ITAT Delhi set aside a reassessment after holding that the ACIT lacked jurisdiction to issue a Section 148 notice. The Tribunal found that the assessee’s returned income was below the CBDT threshold requiring jurisdiction to remain with the ITO.
ITAT Ahmedabad held that transfer pricing authorities cannot assign a NIL arm’s length price when the assessee has demonstrated actual receipt of intra-group services through supporting evidence.
NCLAT held that challenges to the approved resolution plan could not be reopened after earlier proceedings had attained finality. The appeal was dismissed as an attempt to re-agitate settled issues.
CESTAT Chennai held that CENVAT credit cannot be denied where the assessee establishes a real and sufficient nexus between the disputed input services and its output services. The Tribunal found that the Revenue failed to prove otherwise and set aside the credit denial.
The Court held that TDS certificates and income tax filings established a prima facie jural relationship between the parties. It granted interim protection after finding that the respondent could not deny a relationship previously acknowledged before tax authorities.
