ITAT Mumbai held that no extrapolation can be done on estimation basis in absence of any incriminating material. Accordingly, addition rightly deleted by CIT(A). Thus, order of CIT(A) upheld and appeal of revenue dismissed to that extent.
Since the transactions in seized records were only notional mock trading entries and not unexplained cash credits, only brokerage income at 1% of transaction value was taxable.
Assessee, being a charitable trust registered under Section 12A, was entitled to exemption under Sections 10(34) and 10(35) for dividend and mutual fund income therefore, denial of exemption by invoking Sections 13(1)(d) and 13(2)(h) was unjustified
ITAT Delhi remitted a case where CIT(A) upheld additions without examining available evidence. The ruling reinforces that authorities must fully consider documents and explanations before confirming unexplained investments.
The ITAT Mumbai remanded a ₹50 lakh addition case after finding that a business loan was omitted from audited accounts and required further verification.
ITAT Kolkata held that gifts received from a brother-in-law are exempt under Section 56(2)(vii), as the relationship qualifies as relative for tax purposes.
Delhi High Court held that tax authorities cannot replace projected business valuations with actual results when assessing transfer pricing, emphasizing commercial prudence principle in asset transfers.
ITAT Delhi held that penalty under Section 272A(2)(g) cannot be imposed when TDS delay is due to technical reasons and the assessee has already paid compounding charges and interest.
The tribunal dismissed both assessee and Revenue appeals, confirming that income from accommodation entries can be estimated at 5% of credit entries in the bank. The ruling clarifies that when commissions are claimed on transactions without actual goods delivery, a reasonable percentage can be applied to determine taxable income.
ITAT Delhi upheld that non-deduction of TDS on External Development Charges (EDC) paid to HUDA constitutes default under sections 201(1)/201(1A). Following High Court precedent in Puri Construction, the ruling clarifies that such payments attract TDS under section 194C even without a formal contract.
