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214 orders · Page 5 of 5
The Tribunal held that reassessment proceedings cannot be initiated merely on a protective basis or to safeguard revenue interests when the AO himself believes no income has escaped assessment for the current year. The addition was made on a precautionary basis, and substantive addition was made in another assessment year.
The Tribunal upheld the CIT(A)'s decision, noting that the facts were similar to prior years where similar relief was granted and not successfully challenged by the revenue. The Tribunal followed the jurisdictional High Court's judgment on the issue of interest-free advances.
The Tribunal held that merely making an incorrect claim does not automatically attract penalty under Section 271(1)(c), especially when there is a reasonable explanation or the issue is a matter of litigation. The penalty was deleted.
The Tribunal held that merely making an incorrect claim does not automatically attract penalty under Section 271(1)(c). The assessee had a reasonable explanation for the claim, and the issue of capital vs. revenue expenditure is often debatable.
The Tribunal held that the interest paid by the assessee to its AE was at arm's length, following the principle of consistency from previous assessment years. Therefore, no adjustment was warranted.
The tribunal noted the assessee's instruction not to proceed and consequently dismissed the appeal. The appeal was dismissed as not pressed and also as withdrawn.
The Tribunal held that the payment from BCCI was a voluntary contribution with a specific direction to form part of the corpus, thus eligible for exemption under Section 11(1)(d). The Tribunal also upheld the deletion of additions related to advertisement receipts, noting the tax neutrality and correct accounting treatment.
The Tribunal held that expenditure on an abandoned project, where no enduring benefit arises and the project is discontinued, should be treated as revenue expenditure. The CIT(A)'s order was approved.
The Tribunal held that the TPO did not have the statutory power to impose a penalty under section 271G prior to the amendment made by the Finance (No.2) Act, 2014. Therefore, the penalty order was void ab initio.
The Tribunal held that interest income earned on fixed deposits used as security for Letters of Credit in the course of business is eligible for deduction under section 10AA. It also confirmed the disallowance of employee's contribution to PF/ESIC and upheld the CIT(A)'s restriction of disallowance under section 14A to the extent of exempt income.
The Tribunal held that interest income earned on fixed deposits used as security for Letters of Credit in the course of business is eligible for deduction under section 10AA. It also confirmed the disallowance of employee's contribution to PF/ESIC and upheld the CIT(A)'s restriction of disallowance under section 14A to the extent of exempt income.
The Tribunal presumed that the assessee was not interested in prosecuting the appeals. Consequently, the appeals were dismissed for want of prosecution.
The Tribunal, following the Madras High Court's decision in CIT vs. Lakshmi Vilas Bank Ltd, held that software expenditure is revenue in nature. The disallowance made by the lower authorities was deleted.
The Tribunal held that depreciation on vehicles registered in directors' names was allowable as the assessee was the beneficial owner and had incurred related business expenses. The disallowance of labour charges was also deemed unsustainable.