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ITAT Delhi

Addition u/s. 68 deleted as source of funds proved: ITAT Delhi

July 3, 2025 747 Views 0 comment Print

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.

Transfer pricing adjustment by applying Bright Line Test not permissible: ITAT Delhi

July 2, 2025 753 Views 0 comment Print

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.

Income from simulator training to FSTC Dubai was not taxable in India as FTS

July 2, 2025 783 Views 0 comment Print

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.

Section 40A(3) cannot be invoked as income estimated based on gross profit rate

July 1, 2025 675 Views 0 comment Print

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 lack of valid sanction under Section 151

July 1, 2025 1116 Views 0 comment Print

ITAT Delhi quashes reassessment for AY 2016-17, ruling the AO obtained improper sanction from Principal Commissioner instead of Principal Chief Commissioner.

Mere write-off in books sufficient to claim bad debts u/s 36(1)(vii): Delhi ITAT

July 1, 2025 1485 Views 0 comment Print

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.

ITAT Delhi Deletes ₹2 Cr Cash Credit & ₹1.55 Cr Expenditure Due to Lack of Evidence

June 30, 2025 585 Views 0 comment Print

The ITAT Delhi has deleted ₹2 Crore unexplained cash credit and ₹1.55 Crore unexplained expenditure against Shagun Jewellers, citing insufficient evidence.

ITAT dismisses Appeal Due to Non-Representation; Assessee May Seek Restoration Per Rule 24

June 30, 2025 744 Views 0 comment Print

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 quashes reassessment for non-disposal of objections prior to assessment

June 30, 2025 903 Views 0 comment Print

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.

Undated Reasons & Absence of Section 151 Sanction: Delhi ITAT Quashes Reopening

June 30, 2025 693 Views 0 comment Print

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.

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