The Tribunal deleted purchase disallowances after noting invoices, transport records, weighbridge slips, tax returns and bank payments supported actual procurement and use of materials in infrastructure projects.
The issue was whether a share transfer without consideration constituted taxable capital gains. The Tribunal held that genuine family realignment is not taxable.
The Tribunal held that since the Assessing Officer made no addition after verifying disclosures, the grievance lacked merit. Grounds were rightly treated as infructuous due to absence of tax impact.
The Tribunal upheld disallowance of deduction where donations were routed back to donors through layered transactions. The key takeaway is that non-genuine donations do not qualify for tax deduction.
The Tribunal held that trading and service activities were inextricably linked and could not be segmented. It accepted entity-level TNMM, rendering TP adjustments unsustainable.
The Tribunal held that TDS credit cannot be denied merely because it does not appear under the assessee’s PAN. It ruled that the assessee cannot be forced to ensure revision of TDS returns by the deductor.
The Tribunal set aside the dismissal of a delayed appeal, holding that the issue of distribution fee taxability requires fresh examination on merits. The case was remanded to the Assessing Officer for reconsideration with proper hearing.
The Tribunal held that return of advances cannot be taxed under Section 68. The key takeaway is that explained transactions supported by records cannot be treated as unexplained income.
The Tribunal held that delay in filing the return due to pending probate proceedings was beyond the control of executors. It ruled that such delay constituted a bona fide explanation, leading to deletion of penalty under Section 270A.
The Tribunal held that commission paid to foreign agents for services rendered outside India is not taxable in India. Consequently, no TDS obligation arises, and disallowance under section 40(a)(i) was deleted.
