ITAT ruled that the amendment requiring aggregation of consideration under Section 194-IA applies only from October 2024. For earlier years, TDS applicability must be determined individually per buyer-seller transaction.
The Tribunal set aside the order as the CIT(A) failed to examine judicial precedents cited by the assessee. The matter was remanded for fresh adjudication with proper reasoning.
The tribunal held that the holding period of the previous owner must be included when property is acquired through inheritance or trust devolution. As a result, gains were treated as long-term and exemption under Section 54EC was allowed, while Section 54 was remanded for verification.
The case involved denial of deduction due to delayed execution of purchase deed. The Tribunal held that investment in an under-construction property qualifies as construction within the extended time limit. It ruled that deduction cannot be denied on technical interpretation of timelines.
The tribunal ruled that compensation under a government-approved restructuring scheme qualifies as retrenchment. It allowed full tax exemption under Section 10(10B).
The Tribunal upheld deletion of addition as seized loose sheets lacked key details and no supporting evidence proved unaccounted sales. Reliance solely on such documents was held insufficient.
The tribunal held reopening invalid where actual escaped income was below ₹50 lakh. It clarified that jurisdiction depends on real income, not transaction value.
The ITAT Ahmedabad cancelled the penalty under Section 271(1)(c) after setting aside the assessment for fresh adjudication, holding that penalty based on the original order cannot survive once the assessment itself is reopened.
The Tribunal ruled that both conditions for Section 263 revision must exist simultaneously. Since no exempt income was earned, the assessment order was neither erroneous nor prejudicial.
ITAT Ahmedabad held that upward adjustment on account of notional interest on outstanding receivables rightly deleted since TNMM has been applied and working capital adjustment has been given while benchmarking the main international transaction.
