ITAT Judgment contain Income Tax related Judgments from Income Tax Appellate Tribunal Across India which includes ITAT Mumbai, Chennai, Delhi, Kolkutta, Hyderabad etc.
Income Tax : Article examines whether the MLI Principal Purpose Test has domestic effect under Section 90(1) following Nestlé SA and Sky High ...
Corporate Law : The article argues that failure to comply before the AO or CIT(A) can lead to adverse assessments, as higher forums generally cann...
Income Tax : ITAT held that Section 54 exemption must be examined separately for each residential house sold. Aggregating gains from multiple t...
Income Tax : ITAT held that delayed filing of Form 10B cannot defeat Section 11 exemption if the audit report is available before processing un...
Income Tax : Smt. Ranjana Kumari/Kalta Vs DCIT/ACIT (Central) (ITAT Chandigarh) The appeals involved three assessees belonging to the Kalta Gro...
Income Tax : ITAT Bangalore held Section 2(47)(v) inapplicable as the JDA did not satisfy Section 53A conditions, deleting capital gains for AY...
Income Tax : The issue concerns massive backlog in ITAT caused by unfilled positions and delayed appointments. The intervention highlights that...
Income Tax : A representation seeks doubling the SMC threshold due to inflation and higher dispute values. The key takeaway is that increasing ...
Income Tax : The tribunal held that a gift deed alone cannot establish legitimacy under Section 68. It directed fresh scrutiny of the donor’s...
Income Tax : Delhi ITAT allows Sanco Holding, a Norwegian company, to compute income from bareboat charter of seismic vessels under Article 21(...
Income Tax : ITAT Hyderabad upheld the excess cash addition and Section 153D approval, while remanding the stock shortage addition for fresh ex...
Income Tax : ITAT Hyderabad deleted a Section 69 addition after finding the mother's identity, funds and gift confirmation established the sour...
Income Tax : Chennai ITAT deleted the Section 271D penalty, holding temporary cash received to demonstrate visa funds was not a loan attracting...
Income Tax : Chennai ITAT upheld deletion of a Section 69A addition, holding that cash withdrawals from the assessee's own bank account could n...
Income Tax : ITAT Pune upheld deletion of ₹1.14 crore Section 69C addition as it was based only on third-party statements without corroborati...
Income Tax : The ITAT Delhi has revised its hearing notice protocols. Physical notices will now be sent only once, with subsequent dates availa...
Income Tax : ITAT Chandigarh held that ITO Ward-3(1), Chandigarh had no jurisdiction to issue notice to an NRI and hence consequently the asses...
Income Tax : Central Government is pleased to appoint Shri G. S. Pannu, Vice-President of the Income Tax Appellate Tribunal, as President of th...
Income Tax : Ministry of Finance notified rules for appointment of members in various tribunals on 12.02.2020 in which practice of judicial and...
Income Tax : Bhagyalaxmi Conclave Pvt. Ltd. Vs DCIT (ITAT Kolkata) In the remand report, the AO clearly stated that notice u/s 143(2) of the Ac...
The Tribunal found that inadvertent allotment of two PANs led to duplication of bank accounts and misreporting of income. Proper reconciliation was directed before making any addition.
The case examined whether other additions can be made when the reopening issue is not sustained. The Tribunal held that reassessment cannot be used as a roving enquiry.
Registration was denied as activities allegedly exceeded declared aims. The Tribunal held that pending amendment justified remand for fresh adjudication.
ITAT Delhi held that disallowance of bad debts claimed as deduction under section 36(1)(vii) is not justifiable if offered as income in any year. Accordingly, AO directed to verify that amount for which bad debts have claimed u/s 36(1)(vii) were indeed offered as income for the said years.
The Tribunal ruled that loans from salaried relatives with disclosed income and banking trails satisfy identity, creditworthiness and genuineness. The Section 68 addition was therefore unsustainable.
ITAT Mumbai held that where segmental accounts are not available, then proportionate adjustments have to be made only in respect of the international transactions with associated enterprises [AE]. Thus, TPO directed to compute the transfer pricing [TP] adjustment, restricting it to the international transactions undertaken with associated enterprises.
The tax authorities made an addition without examining the lenders bank records. The Tribunal restored the matter to the AO to verify fund availability and absence of cash deposits.
The AO treated loans as unexplained due to incomplete confirmations. The Tribunal confirmed deletion after remand proceedings verified lenders’ identity, capacity, and transaction genuineness.
The reassessment was struck down because it relied exclusively on third-party search material. The ruling clarifies that section 153C, not section 147, must be invoked where incriminating evidence emerges from another persons search.
A Section 57(iii) interest claim was rejected solely due to the loan’s classification as a home loan. The tribunal held that if allowed earlier, the same view must prevail unless facts change.