The assessment notice issued by a Jurisdictional AO post-29.03.2022 violated the faceless assessment scheme, making the income addition void. The tribunal allowed the appeal in favor of the assessee.
ITAT Chennai confirmed that section 234A interest is only compensatory and cannot be charged for periods when no tax remains outstanding. Full payment of self-assessment tax prior to the start of March 2022 negated any basis for levy.
The Tribunal held that Section 44AD could not be applied to a goods carriage business excluded under Section 44AE and restored the matter for fresh examination. The AO must verify conditions under Section 44AE and recompute income accordingly.
The Tribunal ruled that the entity did not qualify as an educational institution or as substantially government-financed, leading to denial of Section 10(23C)(iiiab) exemption. The dispute over taxing gross receipts was remanded for a fresh decision. Key takeaway: fund management alone cannot justify exemption.
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.
