ITAT Delhi held that assessments under Section 153C were without jurisdiction as the satisfaction note was recorded after the Finance Act, 2021 amendment. All six assessment orders were quashed.
ITAT excluded EDCIL, Just Dial, Info Edge and India Exposition Mart as transfer pricing comparables due to functional differences and restored one comparable for verification.
The Delhi High Court held that the issues raised by the Revenue were either covered by binding precedents or based on factual findings of the ITAT. It dismissed the appeal after finding no substantial question of law for consideration.
The Tribunal ruled that a penalty notice lacking a specific allegation of under-reporting, misreporting, or the applicable clause under Section 271AAB is legally defective. It held that such notices violate the requirement of providing a meaningful opportunity of defence.
ITAT held that once Form 10IE is validly exercised and not withdrawn, it continues for later years. AO was directed to grant Section 115BAC benefit.
ITAT deleted the Section 68 addition after holding that the assessee fully established the lender, source of funds and genuineness.
ITAT held that mere transfer of records cannot replace a valid transfer of jurisdiction under Section 127, rendering the assessment invalid.
ITAT held that computer software is eligible for 60% depreciation and directed the AO only to verify its actual cost before computing the deduction.
ITAT held that subsidy recognised as income could be claimed as bad debt when it became unrecoverable, even if written off in the same year.
ITAT held that low declared income alone cannot negate creditworthiness where loans were genuine, documented, received and repaid through banking channels.
