The case examined whether tax authorities could deny working capital adjustment despite clear prior directions of the Tribunal. The ITAT held that such directions are binding and must be implemented in letter and spirit. Once the adjustment was granted, the assessee’s margin fell within the permissible arm’s length rang
The Tribunal held that minor delays in depositing employees’ PF during the COVID-19 lockdown do not warrant disallowance. Considering extraordinary circumstances and statutory relaxations, the deduction was allowed despite the Checkmate ruling.
The Tribunal examined whether provision for salary arrears arising from the Sixth Pay Commission was contingent or accrued. It held that the liability had accrued for services rendered and was allowable as an ascertained liability.
The issue was whether a deductor can be treated as in default for non-deposit of TDS when the payee has already paid tax on the income. ITAT held that no demand under Section 201(1) survives once the payee’s tax payment is established.
The Tribunal examined whether unsecured loans could be treated as unexplained merely on investigation wing inputs. It held that once identity, creditworthiness, and genuineness are proved with documents, additions under Section 68 cannot survive.
The issue was whether income of a predecessor company for years before amalgamation can be reassessed in the hands of the successor. ITAT held that such clubbing is impermissible and the reassessment itself is void.
ITAT Mumbai held that long-term capital gains earned from the transactions, which are grandfathered as per the provisions of Article 13(4) of the India-Mauritius DTAA, doesn’t form part of total income hence cannot be adjusted against the brought forward long-term capital loss incurred by the assessee. Accordingly, order set aside.
ITAT Mumbai held that disallowance on account alleged fictitious trading loss in absence of any direct incriminating material is not sustainable. Accordingly, CIT(A) rightly deleted the disallowance and allowed the appeal of the assessee. Thus, the present appeal by revenue is dismissed.
The PCIT sought to revise the assessment for lack of arms length determination. The Tribunal ruled that the Assessing Officer cannot be faulted when the TPO did not act. The decision reinforces limits on section 263.
The Tribunal held that shares acquired directly from promoters through preferential allotment require strict scrutiny when linked to abnormal price rise. Failure to establish commercial rationale justified restoring the matter for fresh verification.
