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Income Tax : ITAT Bangalore held that additions made in an intimation under Section 143(1) cannot be disputed in an appeal against a scrutiny a...
Income Tax : ITAT Delhi held legal services are not FTS under Section 9(1)(vii) and directed partner-wise DTAA examination. FTS addition was de...
Income Tax : ITAT Mumbai deleted a Section 69 addition after finding documentary evidence established joint ownership, source of funds, and ear...
Income Tax : ITAT Mumbai quashed reassessment after finding no Section 143(2) notice and that the AO issued a final order disguised as a draft ...
Income Tax : ITAT Surat held that delayed filing of Form 10B is a procedural lapse and remanded the matter after directing the AO to consider t...
Income Tax : Instruction No.1/2015 Clarification regarding applicability of section 143(1D) of the Income-tax Act, 1961- Vide Finance Act, 2012...
The tribunal held that merely declaring a low net profit rate cannot justify reopening under Section 147. A valid reassessment requires tangible material and a live nexus with income escapement.
The tribunal held that recomputation of deductions under Sections 36(1)(viia)(c) and 36(1)(viii) involves a debatable legal issue. Such matters cannot be corrected through Section 154 rectification proceedings.
The Tribunal held that reopening AY 2012–13 after a post-2021 search was barred by limitation. Applying Supreme Court guidance, it ruled that older limitation periods protect concluded assessments from retrospective reopening.
Since the mandatory notice was issued by an officer lacking jurisdiction, the assessment was quashed as void ab initio. A valid notice by the correct officer within limitation is indispensable.
The tribunal ruled that reassessment beyond four years is barred when reasons do not allege failure to disclose material facts. Mere suspicion of escaped income is insufficient to override the statutory limitation.
Assessees were qualified as companies owning an industrial undertaking within the meaning of Section 72A. Accordingly, the carry forward and set-off of accumulated business losses and unabsorbed depreciation of the amalgamating transport corporations was allowable.
The ITAT held that unsupported DCF valuation could not justify high share premium. The addition under Section 56(2)(viib) was restored after setting aside the appellate relief.
The ITAT held that reopening an assessment after four years without any new tangible material is invalid. A reassessment based merely on re-examining earlier facts was struck down as a change of opinion.
ITAT Bangalore held that once the genuineness of the building construction expenditure is proved, the consequential claim of depreciation on such genuine assets cannot be denied to trust since depreciation was claimed only on actual assets used for charitable purpose.
ITAT Bangalore held that at the relevant time co-founder of Flipkart stayed in India for 141 days and balance days in other countries. Hence, assessee is an Indian national and thus the appeal of the assessee is dismissed.
