The ITAT Pune held that splitting royalties for domestic vs export sales was impermissible, deleting the entire transfer pricing adjustment. The ruling reinforces that TNMM aggregation for manufacturing includes royalties as a single element.
ITAT Delhi ruled that policy advocacy for EU businesses in India is charitable, as it has no profit motive and benefits the public. CIT(E)’s denial was set aside, and 12A registration restored.
ITAT restored the matter to the Assessing Officer since the assessee’s application for delayed 12A registration and condonation under Section 119(2)(b) was still undecided. The ruling underscores that exemption eligibility must be re-examined only after the competent authority disposes of the registration request.
ITAT clarifies that capital gains arise on the date of JDA execution, not registration, and allows reassessment if the agreement is cancelled before possession transfer.
ITAT Kolkata upheld deletion of ₹8.70 crore addition under Section 68, ruling that proper evidence and confirmations by loan creditors absolved the assessee. Arbitrary AO findings cannot justify tax.
The Court held that a GST demand for a pre-liquidation period could not be enforced after the corporate debtor was sold as a going concern with NCLT confirmation. It ruled that all past dues stood extinguished and the tax proceeding was invalid.
The Court confirmed that statements recorded during a survey cannot form the basis for tax additions if the assessee is not allowed to challenge them.
Court noted that documented share purchases, demat holdings, and stock-exchange sales were not properly evaluated by the AO. The ITAT’s factual findings were upheld.
The Court held that a provisional attachment cannot continue beyond one year under Section 83 and ordered release of the account with a requirement to maintain a ₹10 lakh minimum balance.
The Delhi High Court upheld ITAT’s order, ruling that no incriminating material was seized, and investor companies had sufficient net worth. Additions under Sections 68 and 153A were not justified.
