ITAT Delhi directed that a trust lacking 12A registration cannot be taxed on gross receipts; only surplus income applied outside charitable purposes is taxable.
LL Global Inc. Vs ACIT (ITAT Delhi) ₹50 Lakh Threshold Is Mandatory: ITAT Delhi Quashes Reassessment of Foreign Company as Time-Barred Delhi ITAT (Bench ‘D’) quashed the reassessment proceedings initiated u/s 147 r.w.s. 148, holding them to be barred by limitation under the amended law. The Tribunal noted that the notices u/s 148 were issued […]
ITAT Delhi ruled that CIT(E) cannot evaluate the merit of charitable activities when granting 12AB/80G registration, restoring the trust’s exemptions. Procedural overreach by tax authorities cannot deny valid registration.
ITAT Delhi ruled that a sub-broker’s turnover includes only brokerage income, not total client transactions, and deleted ₹1.5 lakh penalty under Section 271B.
ITAT allowed condonation of a 321-day delay in appeal filing, emphasizing procedural fairness when assessment orders are delivered electronically.
The issue was whether interest on INR-denominated CCDs should be benchmarked using LIBOR or domestic rates. The Tribunal held that PLR applies, rendering the transfer pricing adjustment unsustainable.
The tribunal ruled that an assessment order signed manually instead of digitally in e-proceedings violates binding CBDT instructions and is legally void.
The tribunal held that foreign exchange fluctuation loss was deductible as it was recorded under a consistent mercantile accounting system and in line with applicable accounting standards. The ruling reiterates that such losses are allowable when gains are similarly taxed.
Delhi ITAT held that a bank’s valuation report obtained post-search is not incriminating material, restricting unexplained investment addition to a reasonable estimate.
ITAT Delhi held that additions under Section 69C cannot be made if the AO exceeds the scope of directions issued under Section 263, emphasizing procedural compliance.
