ITAT Mumbai held that the CPC could not withdraw an already allowed Section 10AA deduction through rectification without recording reasons. The Tribunal restored the deduction after finding no material justifying the action.
The ITAT held that the CIT(A) has no power to dismiss an appeal merely for non-prosecution. The appellate authority must adjudicate every appeal on merits and provide reasons as required under Section 250(6).
The ITAT Hyderabad held that certified segmental financial information could not be rejected mechanically without identifying defects. It remanded the issue to the TPO for fresh consideration.
The ITAT Hyderabad held that payments made for Google AdWords constitute advertising contracts under Section 194C and not fees for technical services under Section 194J. The Tribunal ruled that the automated platform did not involve the rendering of technical services to the advertiser.
The ITAT Mumbai held that penalty under Section 270A cannot be sustained where the show cause notice and assessment order fail to specify whether the allegation is under-reporting or misreporting of income. The Tribunal upheld deletion of the penalty after finding the notice lacked a definite charge.
The ITAT Lucknow upheld deletion of the addition after finding that the cash deposits represented business receipts arising from disclosed sales and were duly recorded in the books of account. It held that section 69A could not be invoked on the facts of the case.
The ITAT Delhi deleted the addition under section 69A after finding that the assessee had substantiated the source of the jewellery through a Will, affidavit, purchase bills, bank statements, and other documentary evidence. It held that the jewellery stood satisfactorily explained.
The ITAT Raipur upheld the disallowance of 12.5% of disputed purchases after finding that the assessee failed to establish the actual physical movement and consumption of the goods. The Tribunal held that invoices, banking records and GST documents alone were insufficient in the absence of supporting transport and production evidence.
The ITAT Delhi upheld the deletion of an ₹80 lakh addition after holding that the assessee had established the identity, creditworthiness and genuineness of the lender companies. The Tribunal ruled that additions cannot rest solely on suspicion of circular transactions without corroborative evidence.
ITAT Chennai held that Assessing Officer should have allowed 200% weighted deduction on DSIR-certified capital expenditure under section 35(2AB). It also directed verification of uncertified scientific research expenditure for deduction under section 35(1)(iv).
