Delhi High Court ruled that expenditure cannot be disallowed under Section 14A unless exempt income is actually earned in the relevant year.
Delhi High Court held the ITAT failed to properly examine the ‘make available’ test for secondment payments, set aside its order, and ruled for the Revenue.
The High Court held that the assessment was time-barred as it was not completed within the mandatory period under Section 144C.
The Delhi High Court held that an assessment relying on a seized document and its author’s statement cannot be sustained without providing a real opportunity for cross-examination. The matter was remitted for fresh adjudication.
The Delhi High Court held that a reassessment notice issued beyond the prescribed limitation period was without jurisdiction. It quashed both the Section 148 notice and the consequential assessment order.
The Delhi High Court held that borrowing funds to repay an earlier loan falls within the assessee’s commercial wisdom. It upheld the allowance of related expenditure and dismissed the Department’s appeal.
The High Court held that proceedings under Section 153C cannot be initiated without incriminating material relating to the specific assessment year. It quashed the notice and all consequential proceedings.
The Delhi High Court held that the final assessment order was passed beyond the mandatory limitation period prescribed under Section 144C(13). It upheld the ITAT’s decision and dismissed the Revenue’s appeal.
The High Court held that no addition under Section 68 could be sustained as the Revenue failed to produce material connecting the assessee with the cash deposited in another company’s bank account.
The High Court upheld the ITAT’s order after finding that the Revenue failed to establish any perversity in the concurrent factual findings regarding share capital, unsecured loans and earnest money.