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 the validity of reopening and multiple expense disallowances. While relief was granted on cash payments and reimbursed interest, statutory interest on taxes was held to be non-deductible.
ITAT Pune held that penalty not leviable under section 270A of the Income Tax Act since show cause notice failed to specify the applicable limb u/s. 270A(9) under which the penalty was imposed. Accordingly, penalty is quashed and appeal is allowed.
ITAT held that assessing an AOP without initiating reassessment proceedings against it is impermissible in law. The entire reassessment was declared non-est and additions were deleted.
The Tribunal held that the first appellate authority has a statutory duty to decide grounds on merits and cannot dismiss them as not adjudicated for want of details. Orders violating sections 250(6) and 251(1) were set aside and remanded for fresh adjudication.
The Tribunal held that land cost must be allocated based on saleable/built-up area under the JDA, not total land area. It directed adoption of a higher per-sq-ft land cost while recomputing capital gains.
The Tribunal held that an enforceable agreement to sell, supported by advance consideration, constitutes transfer under Section 2(47), entitling the assessee to Section 54 relief.
The Tribunal examined whether a single satisfaction note could sustain reassessment proceedings for multiple years under section 153C. It held that a composite satisfaction is valid when based on common seized material spanning several assessment years.
The Tribunal held that once a Section 263 revision is set aside, the consequential assessment has no legal existence. All proceedings based on such assessment automatically collapse.
Holding Section 54F to be a beneficial provision, the Tribunal applied settled judicial principles to allow exemption where substantive conditions were met, directing deletion of the capital gains addition.
The Tribunal held that reassessment fails when the show-cause notice is issued on an incorrect factual premise. Jurisdiction under section 147 collapses if the foundation under section 148A is flawed.
