Tribunal observed that it is for the businessman to decide how to organise business finances unless there is evidence of tax evasion. It deleted the Section 68 addition after finding that the assessee had adequately explained the source of funds.
ITAT Delhi held that merely reflecting depreciation in an incorrect schedule of the income tax return could not justify an addition under Section 69. Following its earlier decision in the assessee’s own case, the Tribunal upheld deletion of the addition and dismissed the Revenue’s appeal.
The ITAT Delhi held that the Transfer Pricing Officer could not arbitrarily determine the arm’s length price of management services at nil despite evidence establishing receipt of services. The Tribunal restored the assessees TNMM-based benchmarking by following its earlier decision.
ITAT held that interest earned by a co-operative credit society from deposits with a co-operative bank remained attributable to its business of providing credit facilities. The deduction under Section 80P(2)(a) was therefore allowed.
ITAT Delhi held that Section 56(2)(viib) could not be invoked where shares were allotted at a premium to a 100% holding company. The Tribunal upheld deletion of the addition, finding that the transaction did not defeat the purpose of the deeming provision.
The ITAT Delhi held that Section 56(2)(viib) was not attracted where shares were allotted to existing shareholders without any change in ownership or control. It deleted the addition after finding that the purpose of the deeming provision was not defeated.
The ITAT Delhi held that a common satisfaction note covering multiple assessment years without year-wise incriminating material could not validly confer jurisdiction under Section 153C. It consequently quashed the assessment.
The ITAT Delhi held that the Assessing Officer failed to record that the seized material had a bearing on the determination of the assessees total income, rendering the Section 153C proceedings invalid. The assessments for multiple years were consequently quashed.
The ITAT Delhi held that a single satisfaction note covering multiple assessment years without identifying year-wise incriminating material could not confer valid jurisdiction under Section 153C. It consequently quashed the assessment.
The ITAT Delhi held that a single consolidated satisfaction note covering multiple assessment years without year-wise incriminating material could not validly confer jurisdiction under Section 153C. It quashed the assessments after following the Delhi High Court’s ruling in Shaksham Commodities Ltd.
