The Tribunal held that a transfer pricing reference made after expiry of assessment limitation is void. Once time has run out under section 153, subsequent TPO action cannot resurrect the assessment.
The Tribunal ruled that once the original notice itself is jurisdictionally invalid, later compliance with section 148A is irrelevant. Foundational defects cannot be remedied procedurally.
The Tribunal held that when sales are not disputed, the entire value of alleged bogus purchases cannot be added under section 69C. Only the embedded profit element is taxable.
The assessment was quashed because the mandatory notice under section 143(2) was issued by an officer lacking jurisdiction. The ruling confirms that jurisdiction must exist at the notice stage itself.
The Tribunal ruled that AMP expenses incurred by a brand-owning trader cannot be allocated to contract manufacturers without proof of obligation or agreement. Tax incentives enjoyed by related entities alone were held insufficient.
ITAT held that dismissing a ground without reasons violates appellate duty. The 43B disallowance was remanded for fresh, reasoned adjudication.
The Tribunal held that profit estimation cannot rest on conjectures or lump-sum allegations. In absence of identified bogus purchases or factual basis, the entire addition was deleted.
Delhi ITAT held that a purchase-return mismatch does not constitute misreporting under section 270A(9). Immunity under section 270AA was granted, quashing the ₹10.69 lakh penalty.
The Tribunal held that once cash received was accepted in assessment without any addition, penalty for alleged violation of Section 269SS could not be sustained.
The issue was whether foreign exchange fluctuation loss recorded at year-end was notional and disallowable. The Tribunal upheld its allowability, holding that losses accounted under consistent mercantile practice and accounting standards are deductible.
