Lucknow ITAT held that disallowance under Section 14A read with Rule 8D cannot exceed the exempt dividend income earned by the assessee. The Tribunal restricted the addition to the actual exempt income amount.
The Tribunal held that the first appellate authority should reconsider the matter after the jurisdictional High Court decides pending cases concerning alleged bogus purchase bills by rice millers.
Tribunal ruled that once DSIR certifies R&D expenditure under Section 35(2AB), the Assessing Officer cannot disregard the claim without following the statutory procedure. The decision reinforces the importance of DSIR certification in weighted deduction disputes.
The Jodhpur ITAT condoned a 30-day delay in filing an income tax appeal after holding that the delay fell within the Supreme Court’s COVID-19 limitation exemption period. The matter was remanded to the CIT(A) for fresh adjudication.
The Delhi ITAT held that advertisement and marketing expenses could not be treated as an international transaction without evidence of an arrangement with the associated enterprise. The Tribunal deleted the transfer pricing adjustment and rejected the application of the Bright Line Test.
The Jodhpur ITAT held that penalty under Section 272A(1)(d) could not survive where the Assessing Officer completed scrutiny assessment under Section 143(3) after considering replies and documents furnished later by the assessee.
The Delhi ITAT held that informal WhatsApp conversations without corroborative evidence cannot establish unexplained investment under Section 69A. Since no excess jewellery, invoices, or payment proof were found, the addition was deleted.
Mumbai ITAT held that additions for alleged accommodation entries and commission income cannot be sustained solely on retracted statements and third-party Tally data without independent corroborative evidence.
The ITAT Amritsar reduced additions on unexplained cash deposits after considering that the assessee and his wife were senior citizens with no regular income source. The Tribunal allowed part of the deposits as past savings and household cash availability.
The ITAT Amritsar remanded a case involving denial of section 54B exemption where the assessee relied on Girdawari records to prove agricultural use of land. The Tribunal directed fresh verification of land records after finding disputes regarding cultivation entries in revenue documents.
