The Tribunal held that reopening under Section 147 cannot rest merely on information received from the Investigation Wing or Insight Portal. Since the Assessing Officer conducted no independent enquiry or verification, the reassessment proceedings were quashed.
The Tribunal held that offshore supply receipts could not be taxed under Section 44BB where the Revenue failed to prove the existence of a Permanent Establishment in India. The addition of Rs. 99.50 crore was therefore deleted.
ITAT held that execution and registration of a sale deed completes the transfer for capital gains purposes. Delayed receipt of sale consideration or dishonoured cheques cannot postpone taxability when the registered transfer remains valid.
The ITAT Kolkata held that cash payments made through agents for procuring paddy from farmers were covered by Rule 6DD exceptions. Consequently, the disallowance under Section 40A(3) was deleted.
The ITAT Mumbai held that the assessee had satisfactorily explained the source of Rs. 1.25 crore through bank records, PPF withdrawals, and documented fund movements. Since the transactions were verifiable through banking channels, the addition under Section 69 was deleted.
The ITAT Kolkata found that the assessees share capital remained unchanged throughout the year and no fresh capital was received. As a result, the addition under Section 68 for alleged unexplained share capital was deleted.
ITAT Delhi held that a bad debt deduction cannot be denied once the debt is validly written off in the books of account. The Tribunal ruled that proof of actual irrecoverability was not required in view of CBDT circulars and judicial precedent.
The ITAT Kolkata held that the Assessing Officer could not examine issues beyond the limited scrutiny mandate without following CBDT-prescribed procedures for conversion into complete scrutiny. As a result, the interest disallowance under Section 36(1)(iii) was deleted.
The Tribunal deleted the disallowance of advertisement and publicity expenses after finding that sponsorship of football teams, tournaments, and green movement initiatives was undertaken for business promotion. It held that such expenditure qualified as allowable business expenses.
The Tribunal held that delay in filing appeals was justified where the assessee had shifted to a new PAN and filed returns under it. The matter was remanded to the CIT(A) for fresh consideration.
