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 ITAT held that without a condonation petition, a 300-day delay cannot be excused. The ruling underscores that delay must be justified before merits—including Section 80P—can be considered.
The Tribunal ruled that additions based on third-party search without giving the assessee a chance to examine evidence violated natural justice, deleting ₹2.04 Cr and ₹64.11 Lakh for AY 2018-19 & 2019-20.
Commission payments to agents were held genuine for AY 2013-14 and 2014-15. Tribunal directed deletion of disallowances as payments were backed by bank records, TDS, and recipient confirmations.
ITAT Mumbai confirmed loans from Hallow Securities and Dhankalash were genuine, rejecting Revenue’s allegations of shell-company loans. Interest claimed on these loans was also allowed. The ruling highlights the importance of corroborative evidence in section 68 assessments.
The Tribunal held that reopening the assessment on the same grounds already examined in the original scrutiny amounted to an impermissible change of opinion. With no new material on record, the reassessment was found invalid. The ruling reinforces that the AO cannot revisit an earlier view in the guise of section 147 proceedings.
The ITAT held that reassessment notices under section 148 issued to a deceased person are invalid, emphasizing that such notices cannot confer jurisdiction and proceedings are void ab initio.
Tribunal held that MEIS/MLFPS rewards are capital receipts, not income under sections 2(24)(xviii) or 28. The ruling confirms that export-linked duty scrip sales are non-taxable when meant for market expansion.
The ITAT annulled the entire reassessment because the Section 148 notice was issued after the Supreme Court–mandated surviving-period cutoff. The ruling confirms that any notice beyond this timeline is void ab initio.
The ITAT ruled that a vague, copy-paste satisfaction note cannot confer valid jurisdiction under Section 153C. Since no specific seized documents were identified, the entire assessment was struck down.
The Tribunal found that the assessee’s net worth was substantially higher than the value of its investments, creating a presumption that investments were made from own funds. As no interest expenditure was linked to exempt income, the AO’s disallowance under Section 14A was held unsustainable.
