ITAT Mumbai held that in absence of any contrary inference by Transfer Pricing Officer [TPO] in the TP analysis, ad hoc disallowance cannot be restored towards the international transaction of technical service and other transaction. Accordingly, appeal allowed.
ITAT Mumbai held that USD 2.41 lakh deposits in Jersey bank accounts were inherited from the assessee’s parents and not undisclosed foreign income, setting aside the CIT(A)’s addition under the Black Money (Undisclosed Foreign Income and Assets) Act.
The CIT(A) deleted a ₹ 75.5 lakh addition under Section 68 after finding the AO violated natural justice by denying cross-examination of the third-party who provided the statement. The ITAT accepted the reassessment was correctly initiated under Section 147, but the final ruling on the Revenue’s appeal is incomplete.
ITAT found authorities erred by upholding CPC’s denial of exemption solely because assessee filed ITR-7 instead of ITR-5. Ruling emphasizes that denying a just claim over procedural non-compliance causes undue hardship to taxpayer.
ITAT allowed taxpayer’s appeal, holding AO erred by applying Section 50C to cash compensation received for extinguishment of a right to receive flats instead of an actual transfer of immovable property. The order directs deletion of confirmed LTCG addition of Rs. 80.32 lakhs.
ITAT Mumbai held that, in terms of section 194A(3)(v) of the Income Tax Act, co-operative society is not liable to deduction TDS on interest paid or credited on deposits to members before 1st June 2015. Accordingly, order set aside and appeal allowed to that extent.
Loss of ₹7.66 Crore was allowable as bad debt deduction under Section 36(1)(vii), recognising the loss as a genuine business loss arising from NSEL’s operational suspension.
ITAT Mumbai ruled that relief under the first proviso to Section 201(1) is available if Form 26A certifying the deductee’s tax payment is furnished. As the buyer obtained the certificate post-appeal, the case was remanded for verification.
ITAT set aside ex-parte additions for unsecured loans and partner’s capital, ruling that taxpayer had reasonable cause for late submission of evidence due to departure of their accountant and Authorized Representative (AR). Tribunal directed CIT(A) to admit evidence under Rule 46A and decide case on its merits.
Tribunal reversed disallowance of Section 80P deduction, affirming that interest income earned by a co-operative society from deposits with a co-operative bank is eligible for tax benefit.
