ITAT Mumbai deleted additions exceeding ₹10.57 crore made under section 56(2)(vii)(c) after finding that the Assessing Officer wrongly adopted an amended valuation approach retrospectively. The Tribunal upheld the CIT(A)’s deletion in entirety.
The Tribunal ruled that additions proposed by CPC under Section 143(1)(a) ceased to survive after the Assessing Officer deleted them in the final scrutiny assessment order. As a result, further appeals relating to the original intimation became infructuous.
The Tribunal ruled that an assessee following mercantile accounting must offer interest income to tax on accrual basis, irrespective of delayed receipt. Failure to disclose the full accrued amount in the relevant year justified reassessment and addition.
The ITAT Delhi ruled that reimbursement of software costs to foreign AEs on a cost-to-cost basis could not be treated as a profit-generating intra-group service. The Tribunal deleted the transfer pricing adjustment after finding the benchmarking method adopted by the TPO unjustified.
ITAT Mumbai ruled that replacing projected cash flows with actual profits while applying the DCF method is legally impermissible. The decision reaffirmed that DCF valuation is inherently based on future estimates and business expectations.
ITAT Mumbai held that additions under section 68 cannot survive where the Assessing Officer failed to conduct independent verification of alleged accommodation entries. Reliance solely on third-party investigation reports was rejected.
The Tribunal upheld tax addition where agricultural land was acquired below stamp duty valuation and DVO-determined fair market value. It ruled that agricultural status of land does not exclude applicability of section 56(2)(x).
ITAT Ahmedabad held that reassessment under Section 147 was invalid as the Assessing Officer failed to show independent application of mind or establish a nexus between investigation material and escaped income.
ITAT Chandigarh held that cash deposits during demonetization could not be treated as unexplained income since the amounts were recorded as sales turnover in the books and supported by VAT returns.
ITAT Rajkot held that revision under section 263 was not sustainable where the Assessing Officer had already conducted extensive verification of agricultural income and expenses. The Tribunal observed that detailed notices, documentary evidence, and independent inquiries were part of the original assessment proceedings.
