ITAT Bangalore held that no separate benchmarking of royalty payment required when the margin is accepted to be at arms length price (ALP) by the TPO. Thus, appeal of the revenue dismissed.
ITAT Bangalore rules penalty under Section 271B cannot be levied for technical breach without malafide intention, in the case of Chinnayellappa Chandrashekar.
ITAT Kolkata held that interest expenditure incurred on loans taken for acquiring property is allowable as deduction under section 48. However, from Assessment Year 2024-2025, due to amendment in provisions, such expenditure will not be allowed as deduction.
ITAT Chennai held that in view of pending decision before Madras High Court which has a bearing on the assessment, the assessment is restored back to the file of AO with a direction to await the pending decision.
Therefore, the addition made by the AO u/s 68 is sustained. Since, addition u/s 68 has been upheld, the expenditure incurred to earn the above sums are to be added u/s 69C as unexplained expenditure.
ITAT Kolkata held that imposition of penalty u/s. 271(1)(c) of the Income Tax Act untenable without concealment of particulars of income or for furnishing of inaccurate particulars. Accordingly, penalty deleted.
ITAT Delhi held that addition under section 68 towards unexplained income rightly deleted as no adverse incriminating material/ document found in the premises of the searched person. Accordingly, appeal of the revenue dismissed.
ITAT Mumbai held that addition under section 68 of the Income Tax Act made towards penny stock deleted since assessee duly discharged the onus cast upon him and there is no adverse order/penalty order against the Assessee.
ITAT Ahmedabad held that disallowances on account of excess contribution to PF deleted since the same didn’t exceed 27% of the salary and wages in terms of rule 87 of the Income Tax Rules. Accordingly, appeal allowed to that extent.
Analysis of Hyundai Rotem Vs ACIT case by ITAT Delhi on tax assessments, time limits under Section 144C, and procedural compliance for international taxation cases.
