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 : 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 ITAT Delhi invalidated the reopening of an income tax assessment because the assessee had filed a complete return and the AO failed to record valid reasons, highlighting the need for proper statutory compliance in reassessment.
The ITAT Delhi partly allowed the appeal as the AO/TPO selected a company that failed the turnover filter for transfer pricing. Key takeaway: Transfer pricing adjustments must follow proper comparability filters and FAR analysis.
The Tribunal held that shifting a disclosed loss from business to speculation does not amount to under-reporting when the quantum of loss is fully accepted. Since the tax liability remained Nil and no suppression was alleged, section 270A could not be invoked. The penalty was therefore deleted in full.
The Tribunal ruled that the Assessing Officer cannot refer property valuation to the DVO if the registered valuer’s estimate is correct or higher than fair market value, overturning an inflated capital gains addition.
The Tribunal held that penalty cannot be levied without specifying whether the case involved under-reporting or misreporting of income. The AO issued a 200% penalty without identifying the statutory limb or giving reasons. Since the order lacked satisfaction and reasoning, the penalty was quashed.
The Tribunal held that section 69A requires unexplained money or valuables to be found; since only documents showing commission were seized, invoking section 69A was invalid. Only 20% of gross commission was allowed as taxable income.
The Tribunal upheld that the assessee could adopt NAV for one sale and DCF for another, as both are recognized under Rule 11UA. Since the AO failed to show any defect in the valuation reports, the substituted FMV was held invalid. The deletion of the section 50CA addition was confirmed.
The Tribunal held that reassessment was invalid since the original scrutiny had already examined the issue and no fresh information indicating suppression or omission was found. Reopening based solely on a change of opinion was rejected. The ruling reinforces that section 147 requires tangible new material.
The Tribunal held that cash deposits could not be treated as unexplained when the AO had already accepted the related cash sales as part of audited turnover. Since stocks, sales, VAT records, and cash books were undisputed, the addition amounted to double taxation. The entire addition was deleted.
ITAT Delhi held that the assessee is eligible for entire credit of foreign taxes, even if the taxability was nil consequent to the deduction on account of business losses or section 10A exemption. Accordingly, appeal is allowed.
