ITAT held that Section 54 permits exemption where capital gains from more than one residential house are invested in a single residential house.
ITAT confirmed additions under Section 68 after relying on earlier findings that the lender companies provided accommodation entries.
Transfer pricing principles dictate that a captive, risk-mitigated service provider could not be benchmarked against full-fledged, risk-bearing entrepreneurs, companies owning substantial intellectual property, or those generating revenue through software products.
ITAT held Section 43CA did not apply as the flats were booked before the provision became effective, deleting the addition based on stamp duty value.
ITAT Mumbai ruled that the amended first proviso to Section 87A refers to total income and does not distinguish between normal income and STCG taxable under Section 111A. The rebate was therefore held to be available.
The ITAT Mumbai held that the rejection of the assessees certified segmental results was unsupported by cogent material and based on surmises. It directed the TPO to consider the audited segmental accounts while benchmarking the international transaction.
ITAT Mumbai held that a deduction claim supported by prevailing judicial precedents cannot attract Section 270A penalty merely because a later retrospective amendment made the claim inadmissible. The penalty for under-reporting of income was deleted.
ITAT deleted the TP adjustment, allowed 60% software depreciation, but upheld other disallowances, partly allowing the appeal.
ITAT held that the AO could not change the valuation method adopted under Rule 11UA and deleted the addition under Section 56(2)(viib).
ITAT accepted the Section 158A declaration and directed the AO to apply the High Court’s final ruling to the relevant assessment year.
