Income Tax : ITAT held that where sales are not disputed, entire purchases cannot be disallowed. Only 15% profit element was taxed, reinforcing...
Income Tax : The Tribunal quashed reassessment proceedings as they were based on a mere change of opinion without any fresh tangible material. ...
Income Tax : The issue involved levy of late fees on TDS returns processed before statutory amendment. The Tribunal held that absence of enabli...
Income Tax : The Tribunal held that valuation without giving the assessee an opportunity to object violates natural justice. It remanded the ma...
Income Tax : The Tribunal condoned delay due to reasonable cause and addressed valuation mismatch. It remanded the issue for DVO-based reassess...
The tribunal examined whether the reasons given for late filing of the appeal were sufficient. It ruled that routine administrative workload and grievance handling cannot explain a substantial delay.
The tribunal considered whether CPC could rely solely on the original tax audit report to make an adjustment. It held that corrections through revised reports and financial records must be examined before sustaining an addition.
ITAT Delhi deleted additions under Sections 68 and 69C after finding that the assessee received and repaid loans through banking channels with supporting confirmations and evidence.
ITAT Panaji refused to condone an 803-day delay in filing appeals against TDS default orders. The Tribunal held that the appellant failed to provide a credible explanation and therefore dismissed the appeals as time-barred.
The Tribunal confirmed the addition of ₹19.27 lakh under Section 69A after finding that the assessee failed to produce documentary evidence explaining the source of cash deposits. The explanation regarding gold loans and family transactions remained unsubstantiated.
ITAT held that the reassessment notice issued under Section 148 was valid because the Assessing Officer followed CBDT Instruction 1/2022 and the Supreme Court’s decision on reassessment procedures. The Tribunal rejected the argument that the notice was barred by limitation.
ITAT Delhi held that reassessment proceedings are invalid when notice under Section 148 is issued in the name of a company that had already converted into an LLP. The Tribunal ruled that proceedings against a non-existent entity are void in law.
The Tribunal ruled that unverified KOT data and handwritten loose sheets are insufficient to establish unaccounted sales. Additions based on assumptions and unsupported survey statements were deleted.
ITAT Ahmedabad held that upward adjustment on account of notional interest on outstanding receivables rightly deleted since TNMM has been applied and working capital adjustment has been given while benchmarking the main international transaction.
The Tribunal held that a communication proposing adjustment under Section 143(1) is not an appealable order. Only the final intimation determining tax liability can be challenged through an appeal.
