Income Tax : Smt. Ranjana Kumari/Kalta Vs DCIT/ACIT (Central) (ITAT Chandigarh) The appeals involved three assessees belonging to the Kalta Gro...
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Income Tax : Section 154 permits rectification of mistakes apparent from the record in assessment orders, intimations, and TDS/TCS processing s...
Income Tax : Delhi ITAT allows Sanco Holding, a Norwegian company, to compute income from bareboat charter of seismic vessels under Article 21(...
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Income Tax : We have attached a file in excel format. The file contains the format of various details which normally assessing officer asks As...
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 : ITAT Delhi held that interest and dividend earned from co-operative banks qualify for deduction under Section 80P(2)(d). Totgar's ...
Income Tax : Instruction No.1/2015 Clarification regarding applicability of section 143(1D) of the Income-tax Act, 1961- Vide Finance Act, 2012...
The ITAT held that the entire value of purchases from an alleged accommodation entry provider cannot be added as income. It directed the Assessing Officer to tax only the profit element by applying a 5% higher net profit rate.
The ITAT upheld deletion of a ₹6.25 crore addition after finding that the loans were received and repaid through banking channels and supported by documentary evidence. It held that the assessee had established the identity, genuineness, and creditworthiness of the lenders.
Tribunal held that final assessment order was time-barred because it was passed after mandatory period prescribed under Section 144C(13). Assessment was set aside, making remaining transfer pricing issues academic.
The ITAT held that a transfer pricing order issued without authentication or a digital signature is invalid in law. Consequently, it quashed the ₹85 crore transfer pricing adjustment and allowed the assessee’s appeals.
The ITAT held that estimating profit at 8% on deposits in undisclosed bank accounts was excessive considering the nature and margins of the electronics trading business. It reduced the estimated net profit rate to 3%.
ITAT Delhi held that where the variation between the issue price and fair market value is within the 10% safe harbour under Rule 11UA, the issue price is deemed to be the FMV. The addition under Section 56(2)(viib) was therefore deleted.
ITAT Delhi held that a notice under Section 143(2) issued by a non-jurisdictional Assessing Officer without a valid transfer order under Section 127 rendered the assessment invalid. The assessment was quashed without examining the merits.
The ITAT held that Section 50C only substitutes the sale consideration for capital gains computation and does not prohibit deduction of the indexed cost of improvement. The matter was remanded only to verify the amount claimed.
The ITAT held that the royalty and FTS adjustment was excessive and directed the Assessing Officer to apply the 1.9% rate accepted by the CBDT under the Unilateral Advance Pricing Agreement. It treated the APA principles as having persuasive value for determining the arm’s length price.
The ITAT held that the assessee’s exclusion of income based on the Place of Effective Management provisions involved a bona fide and debatable legal issue. It ruled that such a claim could not be treated as misreporting under Section 270A.
