The assessee filed his return of Income on 27.08.2019. After filing the return, assessee received intimation u/s 143(1) of the Act dated 23.03.2021 and found that relief under section 90 of the Act had not been allowed amounting to Rs 73,658/-.
ITAT Bangalore held that delay of 1809 days in filing of an appeal condoned since reasonable cause shown for the delay. Accordingly, appeal allowed and AO directed to allow Foreign Tax Credit after due verification of Form 67.
ITAT Surat held that the delay in filing the appeal before CIT(A) is not deliberate or intentional or due to gross negligence on the part of the assessee. Accordingly, delay of more than 2 years condoned and matter remanded back to CIT(A).
Without purchases, there would have been no sales. AO’s claim of inflated purchases to reduce tax liability was not substantiated, as all 10 transactions of diamond purchase and sale were documented with relevant details.
Addition of Rs.10 Crore under Section 271(1)(c) was not justified as Revenue failed to specify whether the addition was being made alleging concealment of income or for furnishing inaccurate particulars of income.
The assessee is a wholly owned subsidiary of Samsung Electronics Company Ltd. The assessee filed the return of income for AY 2015-16 on 30.11.2015 declaring a total income of Rs. 238,85,10,090/-.
Thus, penalty is not warranted on issues where a substantial question of law exists, indicating that the matter is not free from doubt. Accordingly, we quash the penalty order under section 271(1) (c) of the Act.
The AO added excise duty and sales tax to the total turnover while excluding lease rent and other incomes, categorizing them as “Income from Other Sources” rather than “Business Income”.
ITAT Pune held that penalty under section 271(1)(c)/ 271AAB of the Income Tax Act imposable even in case of voluntary disclosure or declaration or surrender per se of income. Accordingly, appeal filed by revenue allowed.
ITAT Ahmedabad held that CIT(A) dismissed the appeal due to non-compliance of the opportunities granted to the assessee. Accordingly, cost of Rs. 10,000 imposed on the assessee and matter remanded back to CIT(A).
