The Tribunal noted that amendments introduced by the Finance Act 2024 permit fresh filings after commencement of activities. The delayed application was remanded to the CIT(E) for consideration under the revised provision.
ITAT held that the AO’s 8% estimation had no support from comparables or past margins. Applying consistency with earlier family-group cases, profit was fixed at 4% and the unexplained investment addition became academic.
ITAT Chennai held that neurology conferences and workshops squarely fall within the ambit of education under section 2(15) of the Income Tax Act. Hence, exemption under section 11 cannot be denied. Accordingly, appeal allowed.
ITAT Chennai held that since there was sufficient own funds to make investment/advances to its subsidiary, the interest disallowance under section 36(1)(iii) was not warranted. Accordingly, AO directed to delete the addition.
Assessments on foreign-sourced income were deleted after the ITAT confirmed the assessee’s Non-Resident status under Explanation 1(a) of Section 6(1).
The Tribunal held that ad agencies operate on low margins, and without comparables, an 8% estimate was excessive. Past history was accepted as the best guide, reducing profit estimation to 5% and deleting cash-deposit addition as double counting.
Tribunal held that a notice issued by JAO under Section 148 is invalid, emphasizing that only FAO-issued notices comply with faceless reassessment rules. Revenue may seek revival if Supreme Court changes legal position.
The ITAT held that reassessment notices must be issued through NFAC under the 2022 Faceless Scheme. A JAO-issued notice violates the mandatory procedure and stands invalid.
The appellate orders for AY 2012-13 & 2013-14 were set aside as the deceased assessee was not heard. The legal heir is now allowed to present documents and have the appeal adjudicated afresh.
The tax authority’s assessment and penalty were set aside as the assessee was not given a fair opportunity to submit documents or Rule 46A application. The court emphasized adherence to natural justice before rejecting section 54F claims.
