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 : 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...
ITAT Delhi upheld addition of Rs. 2.78 crore after finding that the assessee had voluntarily admitted undisclosed stock during survey and post-survey proceedings. The Tribunal held that later retraction without supporting evidence could not displace signed statements and inventory records.
ITAT Hyderabad held that the reassessment notice issued for AY 2015-16 after 31.03.2022 was barred by limitation under the first proviso to Section 149 and therefore invalid.
Delhi ITAT Restricts Corporate Guarantee Fee to 0.30% After Finding Actual Interest Saving Was Only 0.60%; Holds TP Adjustment Must Reflect Real Benefit From Corporate Guarantee.
The case involved additions based on seized diaries, alleged cash sales, and estimated profits. The ITAT partly accepted the assessee’s arguments and directed adoption of a revised industry GP rate for computing taxable income.
Eempt income, which were disallowed under Section 14A could not be automatically added back to compute the book profit for Minimum Alternate Tax (MAT) under Section 115JB without pinpointing real, actual expenditures recorded in the books of accounts by tax authorities that possess a direct nexus with the tax-free earnings.
ITAT Bangalore held that sale of 25 plots did not amount to an adventure in the nature of trade because the properties were held for six years as investments. The Tribunal ruled that mere multiplicity of plots sold cannot by itself convert capital gains into business income.
The Tribunal held that joint ownership alone cannot restrict Section 54 deduction where the entire source of investment for the new residential property originated from the assessee.
The Tribunal deleted penalty under Section 271(1)(c) after substantially deleting the unexplained cash credit addition under Section 68. It held that penalty cannot survive when the quantum addition is largely removed and the remaining amount is estimated.
ITAT Delhi held that additions based on documents seized from a third party cannot be made under Section 143(3) without invoking reassessment proceedings under Section 148. The Tribunal quashed the assessment for non-compliance with mandatory statutory safeguards.
ITAT Delhi deleted transfer pricing adjustments after holding that retail and after-sales businesses could not be compared with wholesale trading to OEMs. The Tribunal ruled that comparables must satisfy functional and market similarity under Rule 10B(2).