The Tribunal held that dividend received from identifiable mutual funds through banking channels cannot be treated as unexplained income. It ruled that proper documentation and traceability negate applicability of Section 68.
The Tribunal held that the TPO failed to consider the assessee’s Internal CUP benchmarking despite directions from the DRP. It directed fresh examination using the correct method and excluded certain NCDs from adjustment.
The issue was whether exemption under Section 54 could be restricted to one property. ITAT held that prior to the 2015 amendment, multiple residential properties were eligible, and full deduction must be allowed.
The ITAT held that a 29-day delay in filing Form 10B is a procedural lapse and cannot be the sole basis for denying exemption under Sections 11 and 12. It ruled that substantial compliance and availability of the audit report before processing must be considered. The AO was directed to reassess the exemption claim accordingly.
The Tribunal held that penalty under Section 271(1)(c) cannot be imposed where income variation arises from genuine computational mistakes. It ruled that voluntary correction during assessment indicates absence of intent to conceal income. The penalty was there-fore deleted.
The Tribunal held that dismissal of appeal without clearly pointing out deficiencies and allowing correction violates natural justice. It restored the matter for fresh adjudication on merits.
The Tribunal held that entire purchases cannot be disallowed when corresponding sales are accepted. It upheld restriction of addition to profit element, preventing unrealistic income computation.
The Tribunal held that additions cannot be made merely on survey statements without rejecting books of account or providing proper opportunity. It deleted the addition for alleged underreported profit, emphasizing adherence to due process.
REC Limited Vs ACIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi, adjudicated cross appeals filed by the assessee and the Revenue for Assessment Years (AYs) 2018–19 and 2019–20, along with Revenue appeals for AYs 2020–21 and 2021–22. Since the issues were common across years, the Tribunal disposed of all appeals through a consolidated […]
The Tribunal held that a minor delay in filing Form 10-IC should not deny concessional tax benefits. It emphasized that substantive compliance prevails over procedural defects.
