ITAT Delhi held that discount on issue of Employee Stock Ownership Plan [ESOP] is allowable as deduction under section 37 of the Income Tax Act. Accordingly, additional claim of ESOP expense allowed.
ITAT Delhi remanded the matter back to the file of AO to re-consider the activities of assessee trust vis-à-vis its coverage under charitable activities or General Public Utility.
ITAT Delhi held that Transfer Pricing Adjustment in respect of transaction of payment of royalty is set aside and Transfer Pricing Officer [TPO] is directed to accept the parameters of determination of compensation as accepted in Advance Pricing Agreement [APA].
ITAT Delhi held that the approval granted u/s. 153D in the nature of a ‘technical approval’ in symbolic exercise of powers under s. 153D. Hence, the consequential assessment orders based on such repugnant approval under s. 153D is bad in law in tune with earlier years.
ITAT Delhi held that seized document merely indicates some rates than pinpointing any specific on-money payment or receipt; as the case may be, involving the assessee. Thus, addition is liable to be deleted.
ITAT Delhi held that once the books of accounts are rejected, it doesn’t warrant any adhoc addition. Thus, CIT(A) rightly restricted GP @ 1% instead of 1.5% as estimated by AO. Appeal dismissed, accordingly.
ITAT Delhi held that interest and penalty due to default in payment of license fee is merely compensatory in nature and hence the same is revenue expenditure. Accordingly, PCIT classifying them to be capital expenditure is not sustainable.
Assessee had appealed against the order dated 12.06.2024 and 18.06.2024 passed by Commissioner of Income Tax (Appeals) [CIT(A)] for the AY 2016-17, 2017-18 and 2018-19,challenging the denial of deduction under section 80P(2)(d) on certain interest incomes.
ITAT Delhi rules excise duty refund to Jindal Saw Ltd as capital receipt, not taxable. Cites earlier rulings and applies ‘purpose test’ from Ponni Sugars case.
ITAT Delhi remands loan addition case to AO, citing lack of opportunity for review. Assessee’s loan creditworthiness to be re-examined.
