ITAT Delhi held that revisionary proceedings under 263 of the Income Tax Act justifiable since related-party expenses were accepted without detailed verification. Accordingly, revision is upheld and the present appeal is dismissed.
The Tribunal held that failure to issue a jurisdictional transfer order under Section 127 invalidates the assessment. It ruled that absence of such order renders proceedings void ab initio, irrespective of merits.
The Tribunal held that lack of awareness of the assessment order and limited knowledge of tax law constituted sufficient cause for delay. The matter was restored for reconsideration on merits.
The Tribunal confirmed addition of unexplained investments where the assessee could not substantiate the source of deposits. The ruling reinforces the burden of proof on the taxpayer.
The Tribunal held that wage arrears arising from pay revision constitute an accrued liability from the effective date. The provision was allowed despite later payment and quantification.
The Tribunal supported the CIT(A)s decision to allow a new claim under Section 10A, noting that appellate proceedings are a continuation of assessment and aimed at determining correct tax liability.
The Tribunal held that deduction cannot be rejected merely due to absence of supporting evidence without examining merits. It remanded the matter for fresh verification of the claim.
The Tribunal held that a penalty notice lacking clarity on whether it relates to concealment or inaccurate particulars is invalid. It ruled that such a defect makes the penalty unsustainable.
The Tribunal held that BLT cannot be used for transfer pricing adjustments on AMP expenses. It ruled that no adjustment was warranted based on binding precedents.
The Tribunal set aside additions to book profit after ruling that MAT provisions do not apply to banks established under a special statute. It emphasized that such entities are not companies under the Companies Act.
