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TP adjustment of bareboat charter hire fees deleted as benchmarking approach already accepted in earlier year

November 10, 2025 456 Views 0 comment Print

ITAT Mumbai held that transfer pricing adjustment in relation to international transaction of payment of bareboat charter hire fees is directed to be deleted since benchmarking approach of assessee is already accepted by DRP in earlier years.

Disallowance u/s. 14A while computing book profit u/s. 115JB is not tenable

November 10, 2025 477 Views 0 comment Print

ITAT Ahmedabad held that addition on account of section 14A of the Income Tax Act while computing books profit under section 115JB of the Income Tax Act is not justifiable. Accordingly, addition u/s. 14A deleted and appeal of assessee allowed.

Tax audit not required as turnover didn’t exceed prescribed limit: business loss allowed

November 10, 2025 669 Views 0 comment Print

ITAT Jaipur held that denial to allow the business loss stating the requirement of books of accounts to be audited is not justifiable since turnover during relevant period didn’t exceed the prescribed limit for getting books of accounts audited.

CPC Exceeded Jurisdiction in Disallowing 80P Deduction for AY 2019–20: ITAT Hyderabad

November 10, 2025 696 Views 0 comment Print

ITAT Hyderabad condoned a 290-day delay in filing an appeal, accepting that the order was sent to an old email address and the officer’s illness caused genuine hardship.

ITAT Delhi Partly Deletes Demonetisation Cash Deposit Addition for Lack of Proper Inquiry

November 10, 2025 4458 Views 0 comment Print

The Tribunal reduced unexplained cash deposit addition from Rs.11.59 lakh to Rs.2.59 lakh, noting both the taxpayer and the department failed to fully substantiate their claims during the demonetization scrutiny.

NRI Couldn’t Access Documents in Time — ITAT Restores Property Addition for Fresh Examination

November 10, 2025 516 Views 0 comment Print

ITAT Ahmedabad allowed the assessee a fresh opportunity to explain the source of investment in property under Section 69A. The tribunal noted that being an NRI, the assessee could not access required documents in time, warranting reconsideration by the AO.

ITAT Sets Aside ₹2.47 Crore Addition Due to Non-Consideration of Additional Evidence

November 10, 2025 219 Views 0 comment Print

ITAT Ahmedabad remitted the case back to the AO after CIT(A) upheld an addition of ₹2.47 crore as unexplained share capital. The assessee had provided detailed bank records, personal books, and PAN/ITR proofs which were ignored, violating principles of natural justice.

Treaty Benefits Cannot Be Denied Without Cogent Evidence: ITAT Delhi

November 9, 2025 714 Views 0 comment Print

ITAT Delhi emphasized that Revenue must present convincing evidence of fraud or economic substance absence to deny DTAA benefits, following Delhi HC guidance in Tiger Global International.

Non-Completion of Project Doesn’t Nullify Land Transfer for Capital Gains: ITAT Cochin

November 9, 2025 561 Views 0 comment Print

Tribunal confirmed that incomplete construction does not cancel a transfer under section 2(47)(vi). The matter was remanded for proper computation of capital gains considering partial project completion.

DTAA Benefit Granted on LTCG and Dividends to Cyprus-based company

November 9, 2025 534 Views 0 comment Print

Gagil FDI Limited Vs ACIT (ITAT Delhi) The case concerns Gagil FDI Limited, a company incorporated in Cyprus, which appealed against an assessment order dated 29 April 2024 for the assessment year 2021–22 under Sections 143(3) and 144C(13) of the Income Tax Act, 1961. The primary dispute relates to whether the assessee was entitled to […]

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