The Tribunal affirmed the CIT(A)’s order annulling assessments because the search was not conducted in the assessee’s name. It also noted that the Revenue’s appeals were not maintainable due to the low tax effect.
The ITAT held that the Supreme Court’s COVID-19 limitation extension did not apply to statutory timelines for completing income-tax assessments. It dismissed the Revenue’s recall application and upheld the earlier order quashing the assessment as time-barred.
The ITAT Raipur held that estimated gross profit addition on unrecorded sales cannot be sustained when the Assessing Officer has not rejected the books of account under Section 145(3). The Tribunal deleted the addition after finding the assessment contrary to settled legal principles.
The Karnataka High Court set aside the impugned order after finding that the entire tax demand had been recovered despite an interim judicial stay. It directed refund of the amount recovered beyond the 20% pre-deposit and remitted the matter for fresh consideration.
The ITAT Mumbai held that the assessee’s convertible debentures lacked the liability component required for classification as Compound Financial Instruments. Consequently, they could not be treated as transition amount under Section 115JB(2C).
The Karnataka High Court set aside an assessment order after finding that the assessee was given only three hours’ notice for a video conference despite seeking a later hearing. The matter was remanded with directions to provide a proper opportunity to reply and participate in a fresh hearing.
ITAT Delhi held that cash deposits arising from recorded and accepted cash sales cannot be added as unexplained cash credits under Section 68. The Tribunal found no evidence contradicting the books of account or stock records.
ITAT Mumbai held that Compulsorily Convertible Debentures cannot be equated with call options and that no option premium arose from their issuance. The transfer pricing adjustment was deleted as no taxable income was generated.
ITAT Bangalore held that RBI’s classification of compulsorily convertible debentures as equity for FDI purposes cannot determine their treatment under the Income Tax Act. The Tribunal ruled that interest on CCDs before conversion remains allowable.
ITAT Delhi held that no disallowance under Rule 8D(2)(ii) could be made where investments yielding exempt income were financed from the assessee’s own funds rather than borrowed funds.
