The ITAT Mumbai ruled that income already taxed under a proprietorship cannot be taxed again in a partnership, deleting the estimated 2% addition by CIT(A).
The Tribunal held that the payment to the labour union was backed by a formal settlement under the Industrial Disputes Act involving 26 workers. It ruled that the assessee demonstrated clear business nexus and commercial expediency in resolving labour unrest. The disallowance under Section 37(1) was therefore deleted.
The Tribunal held that reassessment based solely on a vague Investigation Wing alert, without any independent verification or link to the assessee, was invalid. It ruled that the AO failed to record a proper reason to believe and later assessed an unrelated issue. The entire reassessment was quashed for lack of jurisdiction.
The ITAT ruled that a reassessment notice issued by a non-jurisdictional officer is void, quashing a demand of ₹1.01 crore and invalidating the assessment.
The Tribunal reinstated the entire disallowance after finding the purchases completely non-genuine. It held that estimation theory cannot apply where transactions are proven to be sham.
The ITAT Mumbai invalidated the reopening of an income-tax assessment under section 148, holding that no new tangible material was found. Interest income from co-operative banks and other receipts had already been considered in the original assessment.
ITAT Mumbai invalidated the reassessment for AY 2008-09 because the notice under section 148 was issued after the statutory limitation period and contained a clerical error in the assessment year. The ruling underscores the necessity of strict procedural compliance for reassessment.
ITAT Mumbai upholds CIT(A) decision allowing depreciation on goodwill created during amalgamation. Revenue appeals dismissed for 2018-19 and 2020-21 assessments.
The Tribunal restricted on-money profits to 15%, deleted Transfer Pricing additions, and confirmed bogus purchase disallowances. Jurisdictional objections based on CBDT pecuniary instructions were rejected. The case provides guidance on treatment of search-assessment adjustments and substantiation requirements.
The Tribunal held that the appellate authority failed to examine inventory-related documents before sustaining disallowance under section 37(1). The matter was sent back for fresh adjudication with directions to consider all evidence.
