The Delhi ITAT held that where purchases are reflected in accepted sales and closing stock, the entire purchase amount cannot be disallowed. The Tribunal directed the Assessing Officer to restrict the addition to the gross profit element by applying the average GP ratio of the preceding five years.
The Delhi ITAT held that repeated non-compliance with statutory notices transformed the reassessment into a best judgment assessment in substance. Consequently, the CIT(A) was justified in remanding the matter to the Assessing Officer for fresh adjudication.
The Delhi ITAT concluded that the assessee had discharged the burden of proving the three essential ingredients required under Section 68. The Revenue failed to demonstrate that the funds originated from the assessee itself. The decision resulted in the deletion of the entire addition relating to share capital and premium.
ITAT Delhi held that consolidated approvals granted without application of mind under Section 153D were invalid. Consequently, the related assessment orders were declared void and quashed.
The Delhi ITAT held that receipts from sale and restricted use of standard cybersecurity software could not be taxed as Fees for Technical Services. The Tribunal relied on judicial precedents dealing with standardised technology offerings.
The Delhi ITAT held that reassessment notices issued beyond four years were invalid as the Assessing Officer failed to record the assessee’s alleged failure to make full and true disclosure. The addition relating to ₹13.10 crore share application money was consequently set aside.
The ITAT Ahmedabad held that proportionate interest disallowance cannot be sustained without establishing a direct nexus between borrowed funds and interest-free advances. The Tribunal deleted the addition as the assessee had sufficient own funds.
ITAT Delhi held that reassessment cannot survive when additions are made on issues unrelated to the reasons recorded for reopening. The ruling reinforces that the scope of reassessment must remain confined to the original basis of jurisdiction.
The Delhi ITAT held that reassessment initiated beyond three years was invalid because the alleged escaped income represented by profit embedded in commodity transactions was only Rs. 4.27 lakh, far below the Rs. 50 lakh threshold under Section 149(1)(b).
ITAT Delhi confirmed disallowance of a Section 80GGC claim after relying on investigation findings that the political party operated as an accommodation entry provider. The ruling emphasizes substance over form in tax deduction claims.
