The Hyderabad ITAT restored the issue to the Assessing Officer to verify whether project support and business development costs qualify as Head Office expenditure under Section 44C. It held that the classification requires factual verification before deciding the allowable deduction.
The ITAT Delhi held that cash claimed as marriage gifts could not be accepted where the assessee failed to explain why it remained with him long after the marriage. The Tribunal sustained the addition relating to the Shagun amount.
The ITAT held that reassessment proceedings were invalid because the Revenue failed to provide the mandatory approval under Section 151 despite repeated requests under the RTI Act. The Tribunal ruled that such procedural non-compliance violated natural justice and rendered the reassessment void ab initio.
The ITAT held that reimbursement of travel and conveyance expenses to foreign associated enterprises was not liable for disallowance under Section 40(a)(ia). It followed its earlier ruling in the assessee’s own case and dismissed the Revenue’s appeal.
The ITAT held that the entire value of purchases from an alleged accommodation entry provider cannot be added as income. It directed the Assessing Officer to tax only the profit element by applying a 5% higher net profit rate.
The ITAT upheld deletion of a ₹6.25 crore addition after finding that the loans were received and repaid through banking channels and supported by documentary evidence. It held that the assessee had established the identity, genuineness, and creditworthiness of the lenders.
The ITAT upheld deletion of the Section 69A addition after finding that the bank credits were satisfactorily explained as insurance premium collections and related transactions. It held that the Revenue failed to produce evidence contradicting the assessee’s explanation.
Tribunal held that final assessment order was time-barred because it was passed after mandatory period prescribed under Section 144C(13). Assessment was set aside, making remaining transfer pricing issues academic.
The ITAT held that a transfer pricing order issued without authentication or a digital signature is invalid in law. Consequently, it quashed the ₹85 crore transfer pricing adjustment and allowed the assessee’s appeals.
The ITAT held that an opening cash balance cannot be treated as unexplained merely because the previous year’s income tax return reflected nil cash. It deleted the addition after accepting the assessee’s explanation regarding accumulated withdrawals from taxed income.
