ITAT Delhi upheld deletion of ₹60 lakh addition after finding that the assessee furnished confirmations, audited financials, bank statements, and Section 133(6) replies. In absence of direct evidence linking loans to accommodation entries, the addition under Section 68 was held unsustainable.
The AO added expenditure based solely on a mistaken audit report entry. The ITAT deleted the addition after confirming from the concerned party that no transaction occurred.
ITAT held that goodwill arising from acquisition of a business as a going concern represents a bundle of commercial and business rights. Following Supreme Court precedent, depreciation under Section 32 was allowed for AY 2018–19.
The ITAT held that for a builder following the project completion method, income arises on handing over possession and not merely on registration of sale agreement. The addition of entire sale consideration under Section 2(47) was ruled unsustainable.
The Tribunal held that Section 14A cannot be invoked when no exempt income is earned during the year. It deleted both the additional disallowance and the assessee’s own mistaken disallowance.
The ITAT held that leasing hospital property to a group company did not violate Section 13 since trustees’ shareholding was below statutory limits. Denial of exemption under Section 11 and substitution of notional rent were ruled unsustainable.
The Tribunal held that statutory jurisdiction must be strictly followed in income-tax proceedings. In absence of proof of transfer to the assessing ward, the assessment was declared invalid and set aside.
The Tribunal held that failure to provide opportunity to cross-examine foreign information sources amounted to violation of natural justice. Additions based on unverified documents were therefore invalid.
The Tribunal held that interest income arising from working capital used in regular activities retains its character as business income. Section 80P relief cannot be denied merely because income arises as bank interest.
ITAT upheld revision under Section 263 after finding that the AO failed to verify the taxability of ₹669 crore received by a trust under Section 56(2)(x), rendering the assessment erroneous and prejudicial.
