ITAT Delhi held that Transfer Pricing Adjustment made by the revenue on account of administrative support services segment deserves to be deleted since services rendered are in nature of intra group services and not stewardship activity.
Tribunal held that income from international air transport through code-sharing arrangements qualifies for exemption under Article 8 of the India-USA DTAA, as it forms part of aircraft operations in international traffic.
The ITAT Bangalore held that income from tissue culture and nursery operations forms part of agricultural income under Section 10(1) when integrated with land-based cultivation.
ITAT Ahmedabad held that denial of opportunity of hearing while rejecting an 80G(5)(iii) application violates natural justice and remanded the case for fresh adjudication.
The ITAT Chennai held that rejecting agricultural income solely for lack of receipts is unjustified when similar income was accepted in earlier and later years.
ITAT Indore held that Proviso to section 12A(2) was very much available for AY 2018-19. Thus, the assessee is eligible to exemption u/s 11/12 on the basis of Proviso to section 12A(2). Accordingly, appeal is allowed.
ITAT Mumbai held that doubting goods transportation alone cannot justify full disallowance, restricting the addition to 11.54% GP on ₹32.75 lakh purchases.
ITAT Delhi invalidated a reassessment under Sections 144/147, citing mechanical approval by authorities and incorrect statutory references. The ruling reinforces that higher authorities must apply proper legal mind when granting sanction under Section 151.
ITAT observed that applying an upper turnover filter is essential in transfer pricing cases where the assessee’s turnover is much lower. It ordered exclusion of big IT majors from the comparable list and directed fresh computation of ALP.
ITAT Mumbai deleted a penalty under Section 271(1)(c) because the notice failed to specify whether it targeted concealment of income or inaccurate particulars. The ruling highlights the need for clarity in issuing tax penalties.
