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357 orders · Page 1 of 8
The Tribunal held that the assessee had provided sufficient evidence to substantiate the identity, creditworthiness, and genuineness of the transaction, including the source of funds for the investor. The High Court found no substantial question of law arising from the Tribunal's findings.
The Tribunal held that the assessee had provided sufficient evidence to substantiate the identity, creditworthiness, and genuineness of the transaction, including the source of funds for the investor. The High Court found no substantial question of law arising from the Tribunal's findings.
The High Court condoned the delay in re-filing the appeal. It also issued notice to the respondent assessee on the grounds raised by the Revenue, stating that the first issue is also part of another pending appeal.
The Delhi High Court granted the Revenue liberty to withdraw the appeals. The Revenue was given eight weeks to refile the appeals before the appropriate High Court with territorial jurisdiction.
The Delhi High Court granted the Revenue liberty to withdraw the appeals. The Revenue was given eight weeks to refile the appeals before the appropriate court with territorial jurisdiction.
The High Court condoned the delay in re-filing the appeals. It directed that the present appeals be listed along with other pending appeals concerning the same parties and also asked for an update on steps taken regarding certain entities mentioned in the CIT(Appeals) order.
The High Court condoned the delay in re-filing the appeals, subject to the Revenue filing legible copies of annexures. The matters were adjourned for further examination by the Revenue's counsel.
The High Court condoned the delay in re-filing the appeals after the respondent assessee did not oppose the prayer. The matters were then adjourned for further examination by the revenue's counsel.
The High Court condoned the delay in re-filing the appeals. The matters were adjourned to a future date for further hearing and examination of the files by the Revenue.
The High Court condoned the delay in re-filing the appeals after the respondent-assessee did not oppose the prayer. The court granted further time to the appellant-revenue to examine the files.
The High Court condoned the delay in re-filing the appeals. The court also granted the revenue's request for accommodation to examine the files, listing the matters for a future date.
The High Court found no prejudice to either party in the ITAT's decision to remit the matter back to the TPO for further examination. The court agreed that the case required further appraisal by the TPO.
The Delhi High Court noted that the issue had been settled by the Supreme Court in the Ahmadabad Urban Development Authority case. Consequently, the appeals filed by the revenue were closed, and the orders of the Tribunal were sustained.
The High Court found no prejudice to either party in the ITAT's decision to remit the matter back to the TPO for further examination. The court agreed that the case required further appraisal by the TPO.
The High Court found no prejudice to either party in the ITAT's decision to remit the matter back to the TPO for further examination. The court agreed that the case required further appraisal by the TPO.
The High Court found no prejudice to either party in the ITAT's decision to remit the matter back to the TPO for further examination. The court agreed that the case required further appraisal by the TPO.
The High Court found no prejudice to either party in the ITAT's decision to remit the matter back to the TPO for further examination. The court agreed that the case required further appraisal by the TPO.
The Delhi High Court noted that the issue had been settled by the Supreme Court in the Ahmadabad Urban Development Authority case. Consequently, the appeals filed by the Revenue were closed, and the ITAT orders were sustained.
The High Court found no prejudice to either party in the ITAT's decision to remit the matter back to the TPO for further examination. The court agreed that the case required further appraisal by the TPO.
The High Court found no prejudice to either party in the ITAT's decision to remit the matter back to the TPO for further examination. The court agreed that the case required further appraisal by the TPO.
The Delhi High Court condoned the delay in filing and re-filing the appeals. It held that the issue regarding the commercial nature of income for charitable entities had been settled by the Supreme Court's judgment in *Assistant Commissioner of Income Tax (Exemptions) v. Ahmadabad Urban Development Authority*. Consequently, the revenue's appeals were closed, and the Tribunal's orders were sustained.
The High Court of Delhi granted the appellant's request to withdraw the appeal. The Court dismissed the appeal as withdrawn, with liberty granted to the appellant to file a fresh appeal, if necessary, as per the law. No decision on the merits of the case was made. The specific reasons for seeking withdrawal or the implications of filing a fresh appeal were not elaborated upon by the Court.
The High Court disposed of the appeals in terms of its previous judgments on the same issue. However, the final outcome would be subject to the decision of the Supreme Court in pending civil appeals.
The High Court disposed of the appeals in terms of previous judgments by coordinate benches on the same issue. However, the final outcome would be subject to the decision of Civil Appeals pending in the Supreme Court.
The High Court disposed of the appeals in terms of previous judgments by coordinate benches. However, the final outcome is subject to the decision of the Supreme Court in pending Civil Appeals.
The Tribunal upheld the CIT(A)'s decision that there was no back-to-back arrangement and the assessee was the beneficial owner of the fees. Therefore, the assessee was entitled to the treaty benefits under the India-USA DTAA.
The Tribunal upheld the CIT(A)'s decision that there was no back-to-back arrangement and the assessee was the beneficial owner of the fees. Therefore, the assessee was entitled to the treaty benefits under the India-USA DTAA.
The Delhi High Court condoned the delay of 16 days in re-filing the appeal. The Court accepted the reasons provided in the application for condonation of delay. The application for condonation of delay was disposed of. The matter was then adjourned to a future date for further proceedings. No decision was made on the merits of the appeal itself.
The High Court issued notice and allowed the applications subject to just exceptions. The court noted the assessee's contention that the issue is covered by a Supreme Court judgment and that a MAP agreement led to a consistent tax treatment.
The High Court issued notice to the respondent and allowed the applications subject to just exceptions. The court noted the assessee's contention regarding the Supreme Court judgment and the MAP agreement.
The Tribunal erred in not appreciating that the appellant was a society registered under the Societies Registration Act, 1860, and therefore, the maximum marginal rate could not be applied. Furthermore, only the surplus, not gross receipts, should be taxed after allowing expenses.
The High Court noted the Revenue's contention that the Tribunal's view was erroneous as the source of income, which was unexplained share capital/premium, did not change. The court listed the appeal for further hearing.
The Tribunal held that the prerequisite for acquiring jurisdiction under Section 153C of the Income Tax Act was not met. The revenue argued that the assessing officer of the searched person and the other person were the same individual.
The Tribunal erred in not appreciating that the appellant was a society registered under the Societies Registration Act, 1860, and therefore, the maximum marginal rate could not be applied. Furthermore, only the surplus, not gross receipts, should be taxed after allowing expenses.
The High Court noted that the proceedings in question were for AY 2006-2007, which fell outside the determined block assessment period. The court found the issue to be covered by its previous judgment in CIT v. RRJ Securities Ltd.
The Delhi High Court upheld the ITAT's decision, stating that the issue was covered by a previous judgment of the same court. The appeal was therefore closed.
The High Court condoned the delay in filing the appeal. Since the issue was covered by a prior judgment for the same assessee, the Court found no substantial question of law and closed the appeal.
The Delhi High Court condoned the delay in refiling the appeal. The court noted that the issue in this appeal was covered by a previous judgment in a similar case between the same parties.
The High Court noted that questions A, B, and C were covered by a previous judgment. For question D, concerning disallowance under Section 36(1)(iii), the court issued notice to the assessee.
The Tribunal held that the Assessing Officer failed to conduct independent inquiries and corroborate the investigation report. The court found these to be findings of fact and declined to interfere.
The Delhi High Court acknowledged that the ITAT order was based on the precedent case. Consequently, the High Court closed the appeal, accepting the Revenue's submission.
The High Court allowed the applications for condonation of delay, subject to the appellant filing legible copies of annexures. The matters were then listed for further hearing.
The High Court allowed the applications for condonation of delay, subject to the appellant filing legible copies of annexures. The matters were listed for further hearing.
The Tribunal ruled in favor of the assessee, holding that the rent received was composite and taxable under Section 56 as income from other sources. The High Court directed the revenue to produce the complete record, including the lease agreement.
The High Court allowed the applications for condonation of delay, subject to the appellant filing legible copies of annexures. The matters were then listed for further hearing.
The Tribunal had ruled in favor of the assessee. The High Court noted that a coordinate bench had held that the amendment to Section 14A via the Finance Act 2022 is not retrospective.
The High Court condoned the delay in filing the appeal and allowed the revenue to file legible annexures. The court listed the matter for further hearing on the substantive issue regarding the disallowance under Section 14A.
The High Court condoned the delay in re-filing the appeals. The appeals were then closed as the issues were covered by a prior judgment.