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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...
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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...
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ITAT held that revision under Section 263 cannot be invoked when the Assessing Officer has already examined the issue. The ruling emphasizes that mere disagreement with enquiry results does not justify revision.
The ITAT held that reopening was invalid as it was based on the same material already examined during the original assessment. It ruled that reassessment cannot be used to review a concluded issue.
The tribunal held that addition under Section 69C is not valid where expenditure is properly recorded and the source is explained. The key takeaway is that documented transactions through banking channels cannot be treated as unexplained.
ITAT Mumbai held that development fees collected from passengers was earmarked for capital expenditure towards modernisation and development of airport infrastructure and therefore the same could not be treated as revenue income of the assessee.
The Tribunal held that an assessment order passed in compliance with DRP directions cannot be revised under Section 263. It clarified that such orders are not erroneous as the Assessing Officer is bound by DRP’s binding instructions.
ITAT ruled that the amendment requiring aggregation of consideration under Section 194-IA applies only from October 2024. For earlier years, TDS applicability must be determined individually per buyer-seller transaction.
In the absence of proper compliance with Section 65B and failure to establish a clear chain of custody, the digital evidence relied upon by the Revenue lacked legal admissibility and evidentiary value.
The Tribunal found inconsistency between payment date and share allotment date, raising doubts about the transaction. It held that these factual issues require verification. The matter was remanded to the AO for fresh examination.
The court held that reassessment cannot be initiated on issues already examined during scrutiny. It ruled that reopening based on the same material amounts to a change of opinion and is invalid.
Tribunal held that GST-based turnover differences cannot be taxed again when income was already recorded in prior years and notional interest recognized under IND-AS cannot be taxed unless it actually accrues.
