ITAT Delhi held that television channel and content owner companies could not be compared with a content distribution business. The Tribunal directed exclusion of such entities from the transfer pricing comparables list.
ITAT Mumbai held that distribution fees paid to associated enterprises could not be treated as royalty. The Tribunal followed earlier decisions and directed fresh transfer pricing analysis based on proper comparables.
The Tribunal found that the assessee had produced complete evidence proving allotment, holding, dematerialization, and sale of shares through the BSE. Since the Revenue failed to disprove these documents or establish any manipulation by the assessee, the LTCG exemption could not be denied. The additions under Section 68 and for alleged commission were deleted.
TAT Mumbai held that additions under Sections 68 and 69C could not be sustained where the Revenue failed to establish any connection between the assessee and alleged price-rigging operators. The Tribunal found that the transactions were supported by demat records, banking documents, and stock exchange evidence. The LTCG exemption under Section 10(38) was restored.
ITAT Mumbai upheld the order deleting the addition made on account of alleged unexplained cash credits arising from share sale proceeds. The Revenues challenge against the relief granted to the assessee was rejected.
ITAT Mumbai held that an addition under Section 69 could not be sustained merely on the basis of statements recorded from representatives of the builder group. In the absence of incriminating material directly linking the assessee to the alleged cash payment, the addition of ₹31 lakh was deleted.
ITAT Delhi held that the assessees could not substantiate the genuineness of the share transactions underlying the LTCG claims. The additions under Section 68 were sustained after the Tribunal found that the evidence supported the Revenue’s conclusion of accommodation entries.
ITAT Bangalore allowed withdrawal of the appeal after the assessee opted to settle the dispute under the Vivad Se Vishwas Act, 2020. The issue regarding LTCG being treated as business income was not decided on merits.
ITAT Delhi quashed a ₹65 lakh penalty under Section 271D after finding that no assessment was made for the relevant year and no satisfaction was recorded for initiating penalty proceedings. The Tribunal held that the penalty could not be sustained in such circumstances.
The Tribunal examined whether reassessment proceedings could be initiated after the NCLT declared a moratorium under the Insolvency and Bankruptcy Code. It held that fresh assessment proceedings during the moratorium period were invalid and quashed the assessment order.
