Kolkata ITAT upheld deletion of addition relating to alleged bogus penny stock loss after finding that the assessee had furnished contract notes, demat records, broker statements, and bank documents supporting the transactions.
Mumbai ITAT ruled that transfer of professional fees between branches through journal entries did not attract TDS liability. The Tribunal accepted ICAI records confirming the existence of the Ahmedabad branch.
Mumbai ITAT held that the CIT(A) cannot dismiss an appeal merely for non-prosecution without adjudicating the issues on merits. The matter relating to TDS on payments to Facebook Netherlands was remanded for fresh consideration.
The ITAT Raipur held that additions for cessation of liability cannot be made merely because creditor confirmations were not filed when PAN details, ledger accounts, and other records were already submitted.
The Tribunal ruled that margins agreed under a Bilateral Advance Pricing Agreement may be used for non-covered AEs when transactions are functionally similar. The decision emphasized consistency and the lack of separate benchmarking by the TPO.
The Tribunal quashed the assessment after finding that the statutory conditions under Section 153C were not properly satisfied. It held that defective recording of satisfaction vitiated the entire proceedings against the third party assessee.
Mumbai ITAT observed that assessable value under customs law may differ from invoice value and such variation by itself cannot justify addition under Section 69C without further evidence.
The ITAT Surat held that revision under Section 263 was invalid because the Assessing Officer had already conducted inquiries and examined relevant records. Mere discrepancies in Insight Portal GST data were held insufficient to render the assessment order erroneous.
ITAT Surat restored reassessment appeals to the CIT(A) after observing that the assessee should receive one final opportunity to present evidence. The Tribunal imposed costs due to partial compliance before the appellate authority.
Delhi ITAT directed exclusion of a comparable company engaged in video conferencing solutions after noting that the DRP had already found it functionally incomparable to the assessee’s software distribution business.
