ITAT Pune condones significant delay in cooperative society’s appeals, citing Supreme Court ruling emphasizing pragmatic view over technicalities.
ITAT Delhi directs segment-wise ALP, includes Fiberfox comparable, and rejects notional interest on AE dues for Opterna Technologies, remits Section 68 issue.
ITAT Jaipur held that reopening under section 148 r.w.s. 148A is bad-in-law and liable to be quashed in as much as reopening was merely on the basis of change of opinion. Accordingly, appeal of assessee allowed and reopening quashed.
ITAT Bangalore held that disallowance of entire royalty payment by taking ALP at NIL not justified since there is no change in facts, circumstances or functions and hence principle of consistency should be applied.
ITAT Bangalore held that delay of 38 days caused due to mistaken belief of Chartered Accountant (CA) is a sufficient cause and hence condonable. Accordingly, delay condoned and appeal to be decided on merits.
ITAT rules surcharge not applicable for private trust income below ₹50 lakh for AY 2023-24 & 2024-25, citing Araadhaya Jain Trust precedent.
ITAT Mumbai held that mere non-appearance of directors is no basis for invoking provisions of section 68 of the Income Tax Act. Accordingly, addition towards share application money and share premium is liable to be deleted.
ITAT Mumbai held that addition under section 69A of the Income Tax Act on the basis of a third party statement without bringing any corroborative material is liable to be deleted. Accordingly, addition deleted and appeal of assessee allowed.
ITAT Kolkata rules addition under Section 68 for share capital invalid solely due to non-compliance with summons when evidence was furnished.
ITAT Surat sends back transport expense disallowance case to CIT(A), citing improper rejection of assessee’s additional evidence under Rule 46A.
