Penalty under section 271(1)(c) was not to be levied as Explanation 7 to section 271(1)(c), which specifically governs penalty in transfer pricing cases, was neither invoked during the initiation nor discussed while levying the penalty and neither TPO nor CIT(A) ever held that the ALP was computed outside the statutory provisions, or that the study report lacked diligence or was not prepared in good faith.
Ahmedabad ITAT deletes Rs. 2.53 lakh addition for alleged client code modification, citing lack of evidence against taxpayer Sahil Shah.
ITAT Ahmedabad condones 224-day delay for Modi Charitable Trust, remanding 12A & 80G applications due to the trust’s unfamiliarity with e-notices and tax procedures.
ITAT Ahmedabad remands Urmilaben H. Dave Disc Family Trust’s TDS credit appeals for re-examination, citing AO’s failure to process rectification requests.
Ahmedabad ITAT rules against Section 56(2)(x) addition for Deepakkumar Chandulal Shah, citing a title dispute that justified a lower sale price and a stamp duty value difference within the 5% threshold.
The ITAT Ahmedabad has partially upheld an appeal by Parshwanath Realty Pvt. Ltd., allowing 25% of exhibition expenses incurred for a related firm, citing business expediency and indirect benefit.
Ahmedabad ITAT rules in Greenfield Reality case to tax only 8% profit on unaccounted on-money, deleting separate additions for expenses and cash credits.
ITAT deletes interest disallowance under Section 36(1)(iii) for lack of nexus and upholds telescoping of expenses to avoid double addition of unaccounted cash.
ITAT Ahmedabad reviews Sankalp Recreation’s tax appeals concerning unaccounted income, expenses, book rejection, and PF/ESIC disallowances following a search operation.
Income Tax Appellate Tribunal sets aside PCIT’s revisionary order against Synwave Industries, ruling original assessment not erroneous.
