Noting that exemption was allowed in multiple subsequent years on identical facts, the Tribunal rejected the Revenue’s stand. The addition and denial of exemption were accordingly set aside.
The ITAT held that taxing only TDS credit, while leaving the underlying undisclosed commission untaxed, is a patent error. Section 263 revision was rightly invoked to protect revenue.
The ITAT held that revision under Section 263 was invalid because the Assessing Officer had conducted detailed enquiries into goodwill depreciation. A plausible view taken after scrutiny cannot be branded as erroneous.
ITAT held that arm’s length price for electricity supplied to related entities must be benchmarked against the gross tariff charged by the State Electricity Authority. Excluding mandatory charges distorts comparability and is impermissible.
The issue was whether revision under section 263 could be invoked to deny 80P deduction on interest from co-operative bank deposits. The ITAT held that such revision is invalid when the AO has taken a legally settled and permissible view.
The Tribunal held that purchases supported by invoices, e-way bills, banking payments, and valid GST registration at the time of supply cannot be treated as bogus. Subsequent GST cancellation and non-response by suppliers were held insufficient to justify disallowance.
Hyderabad ITAT held that even a delayed return filed during assessment is valid, and absence of mandatory Section 143(2) notice renders the entire assessment void.
The issue was whether the AO could expand a limited scrutiny assessment into a complete scrutiny without approval. The ITAT held that such expansion is invalid without prior PCIT sanction.
The dispute involved alleged non-compliance with mandatory faceless assessment procedure rendering the order non est. The ITAT held that remanding without ruling on section 144B(9) violations is impermissible.
The ITAT corrected its earlier order after noting that the liberty to reopen completed assessments under sections 147/148 was omitted. The ruling clarifies that absence of incriminating material bars search additions but not lawful reassessment.
