ITAT allows deduction of interest paid under capital bond agreement, holding a clear contractual obligation existed; since corresponding interest income was taxed, matching liability must be allowed-disallowance deleted as one-sided taxation is impermissible.
Delay of 208 days condoned on bona fide grounds with ₹1,000 cost; ITAT sets aside ex-parte CIT(A) order, holding denial of hearing violates natural justice, and remands matter to AO for fresh adjudication with full opportunity.
ITAT remands ₹33.12 lakh agricultural income claim due to lack of evidence; holds no proof means taxable u/s 68/115BBE, but grants one more chance for verification, imposing ₹2,000 cost for non-compliance.
Condonation of 100 + month delay allowed on liberal principles with ₹5,000 cost; ITAT holds gross receipts of charitable trust cannot be taxed-even if Sec 11 denied, only net income after expenses is taxable; matter remanded for verification.
TP ruling clarifies that comparables must meet uniform filters, FAR analysis prevails over search matrix, ESOP adjustments require parity, working capital needs scientific computation, and delayed receivables attract LIBOR-based interest.
The Tribunal held that unsigned sanction for reopening invalidates the entire reassessment. It ruled that absence of signature violates mandatory legal requirements under tax law.
The relocation did not lead to structural enhancement of business assets. The Tribunal ruled that such expenses remain in the revenue field. The decision distinguishes between operational and capital expenditure.
The Tribunal accepted the delay caused by representative’s illness as sufficient reason and admitted the appeal. It found that the authority failed to properly assess genuineness of activities. The matter was restored for fresh adjudication.
The Tribunal held that a company engaged in high-end KPO and business solutions could not be compared with a routine captive BPO service provider. It also ruled that a comparable cannot be rejected solely for following a different financial year if reliable quarterly data is available.
The Tribunal upheld TDS liability where tax was deducted only on part of the property value. It ruled that TDS must be applied on the entire consideration for immovable property transactions.
