The Tribunal held that several comparables selected by the tax authorities failed the RPT filter and were functionally dissimilar, warranting exclusion. It ordered verification, directed inclusion of suitable event-management comparables, and remanded the interest-on-receivables and ICDS issues for fresh review.
Tribunal held that earlier expense disallowances were excessive and reduced them to 10% of turnover. The ruling emphasizes that lack of supporting documents justifies estimation but requires reasonable limits.
The PCIT held the AO’s assessment under section 143(3) as erroneous and prejudicial to Revenue, directing fresh verification of various deductions. The assessee argued all claims were correctly examined, questioning the jurisdiction of section 263.
The Tribunal examined the validity of assessments initiated under Section 153C where the Assessing Officer recorded a single consolidated satisfaction note for multiple assessment years. Following binding precedents, the Tribunal held that consolidated satisfaction is a fatal jurisdictional error and quashed the 153C assessments entirely.
The Tribunal noted that the cash was seized in a case involving narcotics, making the assessees story of property-related pooling of funds implausible. With no credible corroboration and significant inconsistencies, the addition under section 69A was upheld. The ruling stresses that factual context can outweigh self-serving explanations.
The ITAT Delhi upheld the allowance of management fees after verifying proper documentation and business purpose, emphasizing that payments to a parent company are deductible if fully supported.
The ITAT Delhi invalidated the reopening of an income tax assessment because the assessee had filed a complete return and the AO failed to record valid reasons, highlighting the need for proper statutory compliance in reassessment.
The ITAT Delhi partly allowed the appeal as the AO/TPO selected a company that failed the turnover filter for transfer pricing. Key takeaway: Transfer pricing adjustments must follow proper comparability filters and FAR analysis.
The assessee showed that the ₹1.11 crore payment was an advance toward a bank-auctioned property, fully supported by bank transfers and later formalised via a registered deed. The Tribunal held that such documented transactions cannot attract section 69. The addition was therefore deleted.
ITAT held that section 263 cannot be invoked unless the PCIT pinpoints an actual error in the AO’s order; since no specific mistake was shown, the revision was invalid.
