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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...
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...
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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 Ahmedabad held that unexplained investment under Section 69 can be taxed only in the year the investment is actually made. Since the property payments were made in an earlier financial year, the additions for A.Y. 2016-17 were deleted.
The ITAT Mumbai deleted a transfer pricing adjustment of ₹61.22 crore after finding the facts identical to an earlier assessment year. It held that a pending High Court appeal does not dilute the binding nature of an unreversed Tribunal decision.
ITAT ruled that determining the arm’s length price of management service fees at Nil without following a prescribed transfer pricing methodology was not sustainable. It upheld the CIT(A)’s order deleting both the management fee and manufacturing segment adjustments.
The ITAT Kolkata held that the reassessment was invalid because the ACIT lacked pecuniary jurisdiction and completed the assessment without lawful transfer of the case. The reassessment order was set aside.
The Gujarat High Court held that the Tribunal rightly deleted the addition after finding that the Assessing Officer had not verified the assessees claim. It ruled that no substantial question of law arose and dismissed the Revenues appeal.
The ITAT Mumbai held that transfer pricing adjustments for intra-group services were unsustainable because the TPO determined the arms length price without applying any prescribed method under Section 92C. It directed deletion of the adjustments on this technical ground.
The Tribunal held that the assessee’s contention regarding ownership of the bank account required proper verification before sustaining the addition under Section 69A. The matter was remanded for fresh adjudication.
The Tribunal held that proceedings under Section 153C were invalid because the satisfaction note did not record that the seized material had a bearing on the determination of the assessee’s total income. The assessment was consequently quashed.
The Tribunal held that the delay was supported by sufficient cause, including the Supreme Court’s COVID-19 limitation orders and an error by the assessee’s counsel. The appeal was admitted for adjudication on merits.
The Tribunal held that additions relating to share capital and share premium required fresh examination after considering the assessee’s documentary evidence and offer to produce investor-company directors. The appeal was allowed for statistical purposes.
