The case examined whether scrutiny selection without meeting CBDT conditions was valid. The ITAT held that failure to satisfy mandatory criteria invalidated the notice and entire assessment.
The tribunal permitted set-off of interest paid against interest earned, finding both were intrinsically linked to business activities. It directed that only net impact be adjusted in capital work-in-progress.
The Tribunal held that the AO exceeded the scope of limited scrutiny by invoking Section 68 without prior approval. The assessment was quashed as legally unsustainable, and the addition was deleted.
ITAT Delhi held that reassessment proceedings for AY 2015-16 could not survive where the Section 148 notice was issued after 1 April 2021. The Tribunal ruled that such notices were barred by limitation and the resulting reassessment was void.
The tribunal held that rental income cannot be taxed as business income when the assessee has diverse business objects. It directed reassessment under the correct income head.
The tribunal held that disallowance of weighted R&D deduction is unsustainable when valid Form 3CM approval is on record. It emphasized that sufficient documentary evidence before the AO supports the taxpayer’s claim.
The assessee explained cash deposits through corresponding withdrawals supported by books and bank records. The Tribunal held that such documented transactions cannot be treated as unexplained income.
ITAT Delhi held that revisionary proceedings under 263 of the Income Tax Act justifiable since related-party expenses were accepted without detailed verification. Accordingly, revision is upheld and the present appeal is dismissed.
The Tribunal held that failure to issue a jurisdictional transfer order under Section 127 invalidates the assessment. It ruled that absence of such order renders proceedings void ab initio, irrespective of merits.
The Tribunal held that BLT cannot be used for transfer pricing adjustments on AMP expenses. It ruled that no adjustment was warranted based on binding precedents.
