ITAT Delhi quashes search assessments, ruling consolidated S. 153D approval for multiple assessees was mechanical, violating judicial mandate for independent application of mind.
ITAT held that provisions taxing difference in stamp value and purchase price apply only to land and buildings, not leasehold rights. Addition of ₹21.95 lakh was set aside.
ITAT Delhi held that since nature of expense i.e. purchase and source of expense not doubted and only genuineness of expense is doubted, the disallowance has to be made under section 37 of the Income Tax Act and not under section 69C. Accordingly, order of PCIT set aside.
SCIPL Vs DCIT: ITAT Delhi deletes huge additions, ruling that WhatsApp Excel sheets are dumb documents. Suspicion isnt evidence; corroboration is mandatory in search assessments. Deletions on alleged foreign fund diversion & bogus expenses upheld.
The ITAT Delhi remanded the ₹3.94 Cr unexplained cash deposit addition against commission agent Manoj Kumar to the CIT(A). The Tribunal ordered a fresh verification of the taxpayer’s cash flow, noting the lack of agreements and reconciliation of deposits with books.
The ITAT Delhi quashed the reassessment against Lombard Portfolio Pvt. Ltd., ruling the Section 148 notice was time-barred. Following the Supreme Court’s mandate in the Ashish Agarwal case.
ITAT Delhi ruled that salary paid to expatriates on local contracts is deductible and that CSR expenditure disallowed under Section 37(1) remains eligible for deduction under Section 80G.
ITAT Delhi held that as per section 144C(13) of the Income Tax Act final assessment order is to be passed within one month from the end of the month in which directions issued by DRP is received by AO. Assessment order passed beyond the period prescribed u/s. 144C(13) is time barred and liable to be quashed.
The ITAT Delhi allowed Manpower Services India Pvt. Ltd. a ₹24.16 Cr deduction u/s 80JJAA, ruling that fixed-term employees qualify under the amended law if PF/ESI conditions are met.
Delhi ITAT ruled that where sales are accepted, full purchase disallowance is unjustified. Citing Bombay HC, it restricted the addition for bogus purchases of Rs. 23.5 Cr to 12.5% profit element.
