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 : 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 : 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 examined whether a large consultancy payment was allowable when the assessee failed to establish its genuineness and business necessity. It upheld the disallowance, holding that mere claims without credible evidence cannot justify deduction of professional expenses.
The assessing authority made a large addition without explaining its nature or legal basis. The Tribunal ruled that such a cryptic order cannot stand and set aside the addition.
The Tribunal observed that the transfer pricing adjustment was based on unexplained margin calculations. A fresh working was directed to ensure accurate benchmarking of international transactions.
High Court quashed the adjustment made in the intimation under Section 143(1) disallowing deduction under Section 10B and declared the rectification order to be null and void as allowability of deduction under Section 10B was examined during regular assessment proceedings and accepted
The issue was whether a DRP-based assessment passed after the statutory period survives. The Tribunal held the delay fatal and quashed the assessment in entirety.
The issue was erroneous recomputation of LTCG causing double taxation. The Tribunal held that credit for LTCG already declared must be given and indexation cannot be curtailed arbitrarily.
Rejecting contradictory treatment, the Tribunal ruled that the Revenue cannot approbate and reprobate by accepting the lender’s scrutiny while taxing the borrower under section 68. The addition was therefore deleted.
The Tribunal confirmed that post-2021 reassessment notices must strictly comply with amended section 151. Non-compliance with the specified approving authority deprives the Assessing Officer of jurisdiction.
Applying the test of human probabilities, the Tribunal ruled that unexplained abnormal sales could not be fully accepted. At the same time, absence of book defects warranted estimation instead of outright section 68 taxation.
The Tribunal ruled that CIT(A) exceeded jurisdiction by remanding a completed scrutiny assessment. The decision clarifies that remand powers apply only to Section 144 assessments, not regular ones.
