The ITAT Ahmedabad held that merely describing a transaction as a loan by one party and a purchase advance by the other could not justify revision under Section 263. As the source of funds was explained and the amount was refunded, no addition under Section 69A was warranted.
The ITAT held that the addition under Section 69A could not be sustained as the assessee had produced land records, agricultural sale bills, and bank statements supporting the agricultural income. The Tribunal found that these documents had been ignored during assessment.
The ITAT Ahmedabad held that the CIT(A) wrongly dismissed the appeal as time-barred despite a condonation application being on record. The matter was remanded for adjudication on merits after condoning the delay.
The ITAT Ahmedabad admitted additional evidence relating to foreign remittances and restored the matter to the DRP for fresh adjudication. It held that the documents were necessary for proper determination of the issues.
The ITAT Ahmedabad held that unexplained investment under Section 69 can be taxed only in the year the investment is actually made. Since the property payments were made in an earlier financial year, the additions for A.Y. 2016-17 were deleted.
ITAT ruled that determining the arm’s length price of management service fees at Nil without following a prescribed transfer pricing methodology was not sustainable. It upheld the CIT(A)’s order deleting both the management fee and manufacturing segment adjustments.
The ITAT Ahmedabad held that the assessee had discharged its burden under Section 68 by producing confirmations, PAN, bank statements and income-tax records. The Revenue’s additions were deleted as no contrary evidence was produced.
The Tribunal ruled that BSNL VRS-2019 compensation qualifies for complete exemption under Section 10(10B) despite the assessee not claiming it in the original return. It directed the Revenue to recompute income and issue the eligible refund.
The Tribunal held that the Assessing Officer exceeded the scope of limited scrutiny by treating capital gains as business income without obtaining mandatory approval for complete scrutiny. The appeal was partly allowed on this technical ground, and the merits were not examined.
The ITAT held that payments made to directors represented arranger fees and not prohibited sub-brokerage under SEBI Regulations. It deleted the entire disallowance under Section 37(1), finding no violation of law.
