ITAT Delhi allowed travelling and visa expenses paid by assessee’s sons as wholly & exclusively for business purposes in overseas education consultancy. The Tribunal emphasized that procedural delay of 5 days should not defeat substantive justice, partly allowing the appeal.
The Tribunal quashed additions for bogus purchases, cash seizures, and transfer pricing adjustments, affirming the AOP’s unified management and correct taxation at the consortium level.
ITAT Delhi restored the matter to AO, allowing the assessee to submit evidence on share and agricultural status of land to correctly determine capital gains.
The Tribunal emphasized that for notices issued before 01.04.2021, the sanctioning power rested solely with the JCIT, making the PCIT’s approval invalid. Consequently, the ₹82.89 crore disallowance and all further proceedings were set aside.
ITAT held that the entire disputed turnover cannot be added when purchases are accepted and books are not rejected. Only the embedded profit is taxable, leading to restriction of addition to 5% of turnover.
ITAT ruled that a scrutiny order cannot override a 143(1) intimation if the AO fails to examine pending 154 grievances. The case was remanded because the core adjustments were never adjudicated.
RBI introduces a uniform framework governing interest rates, premature withdrawal penalties, and deposit treatment to ensure fairness and transparency across Local Area Banks.
The Tribunal held that additions based solely on earlier-year assumptions cannot sustain without year-specific evidence. It found no material to show that current-year sales or debtors were bogus. The takeaway is that assessments must be supported by concrete evidence, not presumptions.
Tribunal rules that Section 54 deduction applies to property purchased outside India before the 2015 amendment, overturning CIT(A) decision.
The Tribunal held that the AO cannot expand a limited scrutiny into full scrutiny without written approval from the Principal CIT. Additions under Sections 2(22)(e) and 69A were struck down, reaffirming that CBDT instructions are mandatory.
