ITAT Bangalore upheld the CIT(A)’s decision that reassessment proceedings for AY 2015-16 were barred by limitation. The Tribunal found no error in relying on the Supreme Court’s ruling on reassessment timelines.
The ITAT held that compensation paid to terminate a land sale agreement was a business expenditure incurred for commercial reasons. The amount could not be treated as part of closing stock and was allowable under Section 37.
The ITAT held that reassessment proceedings were invalid because the recorded reasons for reopening were undated and failed to establish compliance with Section 148 requirements. The assessment was quashed as a jurisdictional defect.
The ITAT held that transfer pricing adjustment was not justified where the foreign LLC’s income was already offered to tax in India by the assessee. The Tribunal deleted the TP addition, finding no profit shifting or tax erosion.
ITAT Kolkata held that TDS under Section 194C was not required on materials purchased for installation work. The disallowance under Section 40(a)(ia) was reduced substantially after excluding the material component.
ITAT Delhi held that a 22-day delay in filing Form 10-IC could not deprive an eligible company of the concessional tax rate under Section 115BAA. The Tribunal treated the delay as procedural and directed recomputation at the lower rate.
ITAT Delhi set aside a reassessment after holding that the ACIT lacked jurisdiction to issue a Section 148 notice. The Tribunal found that the assessee’s returned income was below the CBDT threshold requiring jurisdiction to remain with the ITO.
ITAT Ahmedabad held that transfer pricing authorities cannot assign a NIL arm’s length price when the assessee has demonstrated actual receipt of intra-group services through supporting evidence.
The ITAT Kolkata set aside the appellate order on penalty under Section 270A and remanded the matter to the CIT(A). The Tribunal held that the penalty issue should be reconsidered along with the pending quantum appeal.
The Tribunal held that Section 69 could not be invoked where YEIDA payments were recorded in the books and funded through an RBI-registered NBFC. The ruling emphasizes that explained and documented sources of investment cannot be treated as unexplained investments.
