ITAT Ahmedabad held that addition made on the basis of third-party WhatsApp chat without any incriminating material is unsustainable in law. Accordingly, order of CIT(A) upheld and appeal of revenue is dismissed.
The Tribunal examined whether lease rent and allied charges from an IT Park were business income or property income. It held that systematic commercial operation with integrated services warrants business income treatment.
The issue was whether section 68 could be invoked for alleged on-money payments absent direct evidence. The Tribunal ruled that in the absence of corroborative material, the addition must be deleted.
The issue was whether the full value of alleged bogus purchases could be added to income. The Tribunal upheld that only the profit element embedded in such purchases is taxable, not the entire purchase value.
The issue was whether a reassessment could be framed in the name of a company that had ceased to exist due to amalgamation. ITAT held such an assessment void ab initio, quashing the entire proceedings.
ITAT Mumbai deleted ₹20,000 yearly penalties where assessments under section 153C accepted returned income with no additions, holding notice non-compliance as merely technical.
ITAT Delhi affirmed direction of CIT(A) to take average of prices reported in Kingsman Publication report and New York Board of Trade [NYBOT] price after converting FOB as per Comparable Uncontrolled Price [CUP] for purpose of computing ALP on issue of import sugar.
The issue was whether proceeds from sale of carbon credits constitute business income. ITAT held such receipts are capital in nature and not chargeable to tax, following binding High Court precedent.
Emphasising strict compliance, the Tribunal ruled that assessments under section 153A without prior section 153D approval are invalid. Cross-objections became infructuous once Revenue appeals were dismissed.
The case examined whether general search statements can justify additions under section 68. The Tribunal held that without a cash trail or independent enquiry, such statements cannot override documentary proof.
