ITAT Delhi held that addition under section 68 of the Income Tax Act cannot be sustained as assessee has proved the source of funds for purchase of land made in earlier assessment year. Accordingly, appeal allowed.
ITAT Delhi held that Bright Line Test doesn’t have statutory mandate and cannot be applied for determining Arm’s Length Price [ALP] of Advertisement, Marketing and Promotion [AMP] expense. Accordingly, appeal allowed to that extent.
AO treated this amount as fees for technical services (FTS) taxable in India, and Dispute Resolution Panel (DRP) upheld the assessment. DRP looked into whether the payment made by an Indian company, FSTI, to Ethiopian Airlines (EA) was taxable in India as FTS.
ITAT Delhi held that invocation of provisions of section 40A(3) of the Income Tax Act not justifiable as income is estimated on the basis of gross profit rate. Thus, disallowance u/s. 40A(3) set aside and appeal stands allowed.
ITAT Delhi quashes reassessment for AY 2016-17, ruling the AO obtained improper sanction from Principal Commissioner instead of Principal Chief Commissioner.
The Delhi ITAT ruled that simply writing off a bad debt in the books is enough to claim it under Section 36(1)(vii) of the Income-tax Act, 1961, without needing to prove irrecoverability.
The ITAT Delhi has deleted ₹2 Crore unexplained cash credit and ₹1.55 Crore unexplained expenditure against Shagun Jewellers, citing insufficient evidence.
ITAT Delhi confirms the reassessment of Ram Dev Rice Pvt. Ltd. for AY 2006-07, upholding the addition of Rs. 90 lakh under Section 68 for bogus share capital based on new tangible information.
ITAT Delhi set aside a reassessment where the AO failed to dispose of assessee objections before completing the assessment, citing a violation of mandatory procedure.
Delhi ITAT voids reassessments for Arpit Goel (AY 2009-12) due to undated reopening reasons and lack of mandatory Section 151 sanction, deeming orders void ab initio.