The issue involved validity of penalty proceedings initiated through an unsigned notice. The Tribunal ruled that such a notice is invalid and cannot confer jurisdiction. The decision highlights the mandatory requirement of proper authentication.
The case examined whether property registered in trustees’ names violated Section 13(1)(c). The Tribunal held no violation as no benefit accrued to trustees, allowing exemption under Section 11.
ITAT Mumbai held that payments made to third-party vendors on a cost-to-cost basis, without any value addition by the assessee, should be treated as pass-through costs and excluded from PLI computation.
The Tribunal held that consolidated Excel entries showing aggregate cash sales were insufficient to establish receipt of ₹2 lakh or more in a single transaction, and penalty under Section 271DA could not be sustained.
The Tribunal deleted purchase disallowances after noting invoices, transport records, weighbridge slips, tax returns and bank payments supported actual procurement and use of materials in infrastructure projects.
The issue was whether a share transfer without consideration constituted taxable capital gains. The Tribunal held that genuine family realignment is not taxable.
The Tribunal held that since the Assessing Officer made no addition after verifying disclosures, the grievance lacked merit. Grounds were rightly treated as infructuous due to absence of tax impact.
The Tribunal upheld disallowance of deduction where donations were routed back to donors through layered transactions. The key takeaway is that non-genuine donations do not qualify for tax deduction.
The Tribunal held that trading and service activities were inextricably linked and could not be segmented. It accepted entity-level TNMM, rendering TP adjustments unsustainable.
The Tribunal held that TDS credit cannot be denied merely because it does not appear under the assessee’s PAN. It ruled that the assessee cannot be forced to ensure revision of TDS returns by the deductor.
