ITAT Delhi Strikes Down Addition: Sale share cannot be treated as an unsecured loan (u/s 68). The tribunal deletes the Rs. 1.41 Cr addition on sale consideration receipt, remanding the s. 54F deduction claim for limited verification.
Mumbai ITAT set aside a PCIT’s u/s 263 order, ruling that allowing Section 80G deduction on CSR donations to an approved entity is a debatable issue, which cannot be revised, thereby restoring the AO’s original assessment.
ITAT Mumbai ruled AO cannot override TPO’s ALP for SDTs, allowing full Section 80IA deduction for captive power sales. Confirms Vireet on 14A/115JB.
Mumbai ITAT allowed Mahindra & Mahindra’s appeal, holding that advertisement and sales promotion expenses of ₹3.26 Cr for ‘Mahindra Parts Plazas’—which were owned and operated by distributors—were revenue in nature and deductible under Section 37(1) of Income Tax Act, rejecting AO’s capitalization.
The court held that objections regarding fraudulent transactions, round tripping, and unstamped documents were triable issues for the arbitrator, not the referral court under Section 11 of the Arbitration and Conciliation Act, 1996.
Mumbai ITAT deleted Rs.8.43 Cr addition u/s68. Assessee proved lenders’ identity, PAN, and bank transfers. Suspicion over creditworthiness cannot replace evidence.
Bangalore ITAT restricted the s.69A unexplained cash addition for non-filer Umesh Babu to the peak credit of Rs.12.25 lakhs, rejecting the Rs.ｹ57.10 lakhs addition.
The Income Tax Appellate Tribunal set aside the NFAC’s order against Puvvada Veera Kumar, finding that the CIT(A) failed to consider detailed written submissions uploaded to the portal, necessitating a de novo appeal hearing.
Bangalore ITAT set aside PCIT’s s.263 order, ruling that difference of opinion on profit estimation rate (6% vs 8%) for a contractor isn’t grounds for revision.
ITAT Bangalore ruled that income belongs to the person who actually earned it. Purchases and sales recorded by son, with audited accounts, barred addition in father’s hands.
