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...
This case involved a ₹1 crore cash deposit treated as unexplained by tax authorities. The Tribunal ruled that since the deposit was sourced from earlier withdrawals, the addition was unsustainable.
The dispute centered on profit estimation after reopening for suppressed turnover. The Tribunal affirmed lower NP for animal sales, recognising industry norms and assessee history. The ruling underscores tailoring estimates to trade economics.
It was ruled that money received from a parent through banking channels constitutes an explained source. The addition under Section 69A was deleted as the transaction was fully traceable.
Restoring the Assessing Officer’s findings, the Tribunal ruled that excessive salary to related directors can be disallowed when it substitutes dividend distribution. Reasonableness must be judged against comparable market remuneration.
The issue was whether Section 50 can apply when no depreciation was ever claimed or allowed on cars. The Tribunal held that without actual depreciation, Section 50 cannot be invoked and the addition was deleted.
The Tribunal clarified that confirmation of a Section 14A read with Rule 8D disallowance does not automatically justify penalty. Independent findings showing inaccurate particulars or concealment are mandatory.
The Tribunal held that penalty proceedings fail where notices do not clearly state whether the charge is concealment or inaccurate particulars. Vague notices violate statutory requirements, leading to deletion of penalty.
The issue concerned whether failure to deduct TDS on foreign commission warranted disallowance. The Tribunal held that Section 195 is triggered only when the payment is chargeable to tax in India, reaffirming settled Supreme Court principles.
This ruling clarifies that repayment of loan with interest, coupled with documentary proof, negates allegations of unexplained cash credit. Mere suspicion without defects in evidence cannot sustain an addition.
The Tribunal held that estimating commission income without corroborative evidence is unsustainable. Audited accounts and consistent interest income showed genuine business activity, leading to deletion of the addition.
