The issue was whether interest-free loans to group entities warranted transfer pricing adjustment. The Tribunal held that since business had not commenced and no income was earned, the adjustment was unsustainable.
The issue was whether the Assessing Officer could invoke section 68 in a limited scrutiny case focused on share premium under section 56(2)(viib). The Tribunal held that, without mandatory approval to expand scrutiny, the addition was legally unsustainable.
The issue was whether revision under section 263 was valid for multiple expense claims. The Tribunal held that since the Assessing Officer had examined issues and adopted a plausible view, revision was unsustainable.
The case examined the correct tax rate for a trust formed exclusively for employees’ benefit. The Tribunal held that such trusts are taxable at normal AOP rates under section 164(1)(iv).
The dispute concerned whether reimbursements from an associated enterprise justified a transfer pricing adjustment using the profit split method. The Tribunal set aside the adjustment, directing a fresh FAR analysis before determining ALP.
Appeals were dismissed earlier as time-barred despite sustained efforts by the assessee through grievances. The Tribunal ruled that absence of negligence and bona fide conduct warranted condonation of long delay.
The Tribunal rejected estimated additions based on alleged circular trading due to lack of seized material or cash trail. The key takeaway is that suspicion and presumptions cannot replace evidence in search assessments.
ITAT Mumbai held that TDS credit duly reflected in Form 26AS cannot be denied just because of some procedural lapse. Accordingly, order is set aside and the present appeal is allowed.
The Tribunal found that CIT(A) erred by linking the protective addition to another company. The assessment was remanded for correct identification of the beneficiary.
ITAT Mumbai held that alleged bogus purchases cannot be disallowed when the assessee provides invoices, receipts, bank proofs, and GST compliance. The ruling confirms that suppliers’ non-filing alone is insufficient for disallowance.
