The ruling set aside a large AMP adjustment after finding that commission paid to distributors could not be recharacterized as marketing expenditure. Consistency with prior years played a decisive role in deleting the adjustment.
The dispute centered on whether a reassessment notice was time-barred and sanctioned by the correct authority. The Tribunal held that the reply period under section 148A must be excluded, bringing the notice within three years and validating the sanction.
The dispute centered on whether DRP directions allow completion of assessment beyond statutory time limits. The Tribunal clarified that section 144C does not create an independent limitation period. Procedural timelines cannot defeat the mandatory bar under section 153.
The issue was whether advance money from a failed land deal could be taxed as income. The Tribunal held that without clear forfeiture, section 56(2)(ix) does not apply. Key takeaway: forfeiture is mandatory to tax advances.
The issue was whether a ₹3.05 crore disallowance under section 14A could stand without nexus to exempt income. The ITAT held that only a reasonable amount with clear linkage can be disallowed, capping it at ₹10 lakh.
The issue was whether section 153C could extend beyond six years without discovery of an undisclosed asset of ₹50 lakh or more. The ITAT held that in absence of such asset-based satisfaction, extended jurisdiction is invalid.
The ITAT held that cash redeposited after a clearly documented bank withdrawal cannot be treated as unexplained. The ruling emphasizes that verifiable fund movement defeats section 69A additions.
The issue was whether a reassessment notice issued after the prescribed time limit was valid. The Tribunal held that notices for the relevant year issued after the cut-off date were barred by limitation, rendering the reassessment void.
The ITAT held that land-levelling and fencing expenses are integral to acquiring agricultural land and qualify for section 54B deduction. The ruling clarifies what constitutes eligible investment despite restricting unregistered costs.
The issue was whether penalty for misreporting could be levied when income was disclosed but offered under an incorrect head. The Tribunal held that such a classification dispute does not amount to misreporting and deleted the penalty.
