The Tribunal upheld CIT(A)’s deletion of ₹2.81 crore transfer pricing adjustment, ruling that selected comparables were functionally and financially dissimilar. PSM was maintained as the Most Appropriate Method, ensuring fair benchmarking of international transactions.
ITAT rules that an additional 54B claim omitted in the original return cannot be mechanically rejected. AO must examine the claim on merits, verifying capital gains utilisation and statutory conditions.
ITAT Ahmedabad set aside the ex-parte CIT(A) order confirming ₹36.3 lakh addition for advance rent. The matter was restored to AO for de-novo adjudication, and the assessee was granted full opportunity to present evidence, with a ₹5,000 cost imposed.
ITAT Ahmedabad set aside the ex-parte CIT(A) order where notices were sent to a wrong email ID, causing non-receipt by the assessee. The matter, including Sec.69A addition and denial of cross-examination, was remitted to CIT(A) for fresh adjudication on merits.
ITAT Ahmedabad held that speculative intraday trades are genuine and not accommodation entries. Additions under Section 68 totaling ₹1.25 crore and ₹1.53 lakh were deleted due to lack of foundational facts and proper inquiry.
ITAT Ahmedabad held that reassessment under Section 147 cannot be based on vague or unverified information; specific transactions must be identified to justify additions.
The ITAT determined that the tax department failed to adhere to the statutory deadline for issuing a Section 148 notice, making the reassessment jurisdiction invalid from the start. The ruling confirms that strict adherence to the extended limitation period is mandatory, and failure to comply results in the entire reassessment being quashed.
Assessing the full cash component of a property sale in the hands of one legal heir was found to be factually incorrect, leading the Tribunal to delete the addition. The appellate authority confirmed that the proceeds were jointly receivable by all co-owners and could not be attributed to the Assessee exclusively as unexplained credit.
Tribunal remands the matter after finding that bank records showing cash withdrawals were not examined. The key takeaway is that cash-in-hand cant be treated as unexplained without proper factual verification.
The Tribunal ruled that the Assessing Officer cannot refer property valuation to the DVO if the registered valuer’s estimate is correct or higher than fair market value, overturning an inflated capital gains addition.
