Held that internal CUP [internal Comparable Uncontrolled Price Method] is the most appropriate method for undertaking the determination of Arm’s Length Price.
ITAT Delhi held that that car parking cannot be separated from the main business of SEZ, hence deduction under section 80IAB of the Income Tax Act duly available on income from car parking rental.
ITAT Delhi held that provisions of section 68 of the Income Tax Act cannot be applied in relation to the cash sales receipt shown by the assessee in its books of accounts.
ITAT Delhi held that denial of pre-operative expenses like brokerage and commission expenses, business promotion expenses, vehicle running expenses, etc. intricate to the nature of business activity is unsustainable.
ITAT Delhi held that directions issued by a superior appellate authorities are binding on the Assessing Officers and Assessing Officer is required to strictly follow the directions of the appellate authorities and decide the issue as per the directions of the appellate authorities.
ITAT Delhi held that addition under section 68 of the Income Tax Act unsustainable in as much as identity, creditworthiness of the creditors and genuineness of the transaction duly proved by the assessee.
ITAT Delhi held that reassessment order u/s 147 of the Income Tax Act against a non-existent entity is bad in law and vitiated & nullity.
ITAT Delhi held that addition made by the A.O. in the absence of any incriminating material found during the search operation conducted u/s 132 of the Income Tax Act is liable to be deleted.
ITAT Delhi held that reopening of assessment under section 147 of the Income Tax Act unjustified in absence of failure on the part of the assessee to disclose fully and truly all the material facts.
ITAT Delhi held that penalty u/s 271D of the Income Tax Act is without any satisfaction and, therefore, no such penalty can be levied. Accordingly, penalty u/s 271D quashed.
