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The Tribunal held that the reopening of the assessment under Section 148 was invalid because the Pr. CIT's approval was mechanical and lacked application of mind. Therefore, the assessment framed by the AO was quashed.
The Tribunal held that the PCIT was not justified in invoking Section 263 as the AO had made proper inquiries and considered the assessee's submissions regarding agricultural income. The revision was based on an audit objection, which is not sufficient grounds for revision.
The Tribunal held that such disallowances are not permissible under Section 43B read with Section 36(1)(va) of the Income Tax Act, 1961, if the payments are made before the due date of filing the return of income. This decision followed earlier pronouncements by coordinate benches.
The Tribunal held that such disallowances are not permissible under Section 43B read with Section 36(1)(va) of the Income Tax Act, 1961, if the payments are made before the due date of filing the return of income. This decision followed earlier pronouncements by coordinate benches.
The Tribunal held that such disallowances are not permissible under Section 43B read with Section 36(1)(va) of the Income Tax Act, 1961, if the payments are made before the due date of filing the return of income. This decision followed earlier pronouncements by coordinate benches.
The Tribunal held that such disallowances are not permissible under Section 43B read with Section 36(1)(va) of the Income Tax Act, 1961, if the payments are made before the due date of filing the return of income. This decision followed earlier pronouncements by coordinate benches.
The Tribunal held that such disallowances are not permissible under Section 43B read with Section 36(1)(va) of the Income Tax Act, 1961, if the payments are made before the due date of filing the return of income. This decision followed earlier pronouncements by coordinate benches.
The Tribunal held that such disallowances are not permissible under Section 43B read with Section 36(1)(va) of the Income Tax Act, 1961, if the payments are made before the due date of filing the return of income. This decision followed earlier pronouncements by coordinate benches.
The Tribunal held that such disallowances are not permissible under Section 43B read with Section 36(1)(va) of the Income Tax Act, 1961, if the payments are made before the due date of filing the return of income. This decision followed earlier pronouncements by coordinate benches.
The Tribunal held that such disallowances are not permissible under Section 43B read with Section 36(1)(va) of the Income Tax Act, 1961, if the payments are made before the due date of filing the return of income. This decision followed earlier pronouncements by coordinate benches.
The Tribunal condoned the delay in filing the appeal, considering the reasons provided by the assessee, including the COVID-19 pandemic. The Tribunal then proceeded to decide the substantive issue on merits.
The Tribunal held that such disallowances are not permissible under Section 43B read with Section 36(1)(va) of the Income Tax Act, 1961, if the payments are made before the due date of filing the return of income. This decision followed earlier pronouncements by coordinate benches.
The ITAT held that grounds challenging the legality of proceedings must be adjudicated upon by the lower appellate authority. Since the CIT(A) failed to do so, the matters were set aside to the CIT(A) for adjudication.
The ITAT held that grounds challenging the legality of proceedings must be adjudicated upon by the lower appellate authority. Since the CIT(A) failed to do so, the matters were set aside to the CIT(A) for adjudication.
The ITAT held that grounds challenging the legality of proceedings must be adjudicated upon by the lower appellate authority. Since the CIT(A) failed to do so, the matters were set aside to the CIT(A) for adjudication.
The Tribunal partially allowed the appeal, following its consistent decisions in preceding years. It held that while some adjustment for corporate services might be warranted, it should be restricted based on the benefit derived from financial services. Disallowance of interest expenditure was allowed, and penalty proceedings were deemed premature.
The Tribunal held that the crystallization of liability is key for expenses under the mercantile system, especially when settlements occur in subsequent years. Regarding TDS, it found that the CIT(A) had not properly examined the evidence provided by the assessee.
The ITAT held that the CIT(A) failed to adjudicate on the grounds challenging the legality of the proceedings. Therefore, the matter was set aside to the CIT(A) for a fresh adjudication on these specific grounds after providing an opportunity to the assessee.
The Tribunal partially allowed the appeal, following its consistent decisions in preceding years. It held that while some adjustment for corporate services might be warranted, it should be restricted based on the benefit derived from financial services. Disallowance of interest expenditure was allowed, and penalty proceedings were deemed premature.
The Tribunal held that the Assessing Officer made a proper inquiry and took a possible view supported by Supreme Court judgments, thus the assessment order was not erroneous. The PCIT exceeded his jurisdiction in invoking Section 263.
The Tribunal held that the balance sheet drawn on the date of valuation (March 31, 2016) and subsequently audited satisfies the conditions of Rule 11U(b). Therefore, the FMV determined by the assessee based on this balance sheet is acceptable.
The Tribunal held that while the Assessing Officer's order was erroneous and prejudicial to the revenue concerning investment in a shop construction, it was not so for investments in house construction or VAT penalties. The issue of trading results was also not upheld as erroneous.
The Tribunal held that while the Assessing Officer's order was erroneous and prejudicial to the revenue concerning investment in a shop construction, it was not so for investments in house construction or VAT penalties. The issue of trading results was also not upheld as erroneous.
The Tribunal set aside the ex-parte order of the CIT(A) and remanded the matter back for a fresh hearing. The Tribunal noted that the CIT(A)'s order was contrary to statutory provisions requiring a reasoned written order.
The Tribunal held that while the Assessing Officer's order was erroneous and prejudicial to the revenue concerning investment in a shop construction, it was not so for investments in house construction or VAT penalties. The issue of trading results was also not upheld as erroneous.
The Tribunal held that while the Assessing Officer's order was erroneous and prejudicial to the revenue concerning investment in a shop construction, it was not so for investments in house construction or VAT penalties. The issue of trading results was also not upheld as erroneous.
The Tribunal held that while the Assessing Officer's order was erroneous and prejudicial to the revenue concerning investment in a shop construction, it was not so for investments in house construction or VAT penalties. The issue of trading results was also not upheld as erroneous.
The Tribunal held that while the Assessing Officer's order was erroneous and prejudicial to the revenue concerning investment in a shop construction, it was not so for investments in house construction or VAT penalties. The issue of trading results was also not upheld as erroneous.
The Tribunal permitted the assessee to withdraw the appeals as requested. The assessee was granted liberty to approach the ITAT for restoration if the dispute is not fully settled under the Vivad se Vishwas Scheme.
The Tribunal found that the assessee had opted for the Vivad se Vishwas scheme for penalty appeals, not quantum appeals. The CIT(A) incorrectly treated the quantum appeals as withdrawn. Therefore, the impugned orders were set aside.
The tribunal noted that the assessee intended to withdraw the appeal as the dispute was settled under the Vivad Se Vishwas Scheme. The revenue had no objection to the withdrawal.
The Tribunal condoned the delay, finding sufficient and reasonable cause due to the assessee's mental and physical duress from criminal proceedings and health issues. The appeals were admitted for adjudication on merits.
The Tribunal held that the issue of late deposit of PF is covered in favour of the assessee by various Tribunal orders. The Tribunal also admitted and allowed the additional ground regarding the deductibility of educational cess.
The Tribunal condoned the delay, finding sufficient and reasonable cause due to the assessee's mental and physical duress from criminal proceedings and health issues. The appeals were admitted for adjudication on merits.
The Tribunal condoned the delay, finding sufficient and reasonable cause due to the assessee's mental and physical duress from criminal proceedings and health issues. The appeals were admitted for adjudication on merits.
The Tribunal held that the claim was an incorrect claim, not a false claim, as all particulars were disclosed. Relying on Supreme Court judgments, it was decided that a bonafide mistake does not attract penalty when all facts are disclosed.
The Tribunal admitted the additional evidence and restored the appeal to the file of the CIT(E). The CIT(E) was directed to reconsider the assessee's application for registration after considering the new evidence and providing an opportunity to the assessee.
The Tribunal held that the property sold was an industrial plot, not a residential house, and therefore, the deduction under Section 54 was not admissible. The assessee was eligible for deduction under Section 54F.
The Tribunal held that the amendments made by the Finance Act, 2021 to Sections 36(1)(va) and 43B are prospective and not retrospective. Therefore, the disallowance made by the AO and confirmed by the CIT(A) is not sustainable as the deposit was made within the due date of filing the Income Tax Return.
The Tribunal held that the amendments made by the Finance Act, 2021, to Sections 36(1)(va) and 43B are prospective, not retrospective. Therefore, the disallowance of the employee's contribution, deposited before the return filing due date, is not sustainable.
The Tribunal held that the amendment brought by the Finance Act, 2021, is prospective and not applicable to the assessment year 2018-19. Payments made before the due date of filing the return are allowable.
The Tribunal held that the disallowance for late deposit of ESI and PF contributions was not sustainable as the deposits were made before the due date of filing the return of income, and the amendment by the Finance Act, 2021, was prospective. The Tribunal also held that the disallowance for provision for gratuity was incorrect as the assessee had already suo-moto disallowed it in its computation of income, leading to double taxation.
The Tribunal held that disallowances for delayed PF & ESI deposits, when made before the filing of the return of income, cannot be made under Section 43B or Section 36(1)(va) of the Income Tax Act. The Tribunal followed its earlier decisions on this issue.
The Tribunal held that disallowances for delayed PF & ESI deposits, when made before the filing of the return of income, cannot be made under Section 43B or Section 36(1)(va) of the Income Tax Act. The Tribunal followed its earlier decisions on this issue.
The Tribunal held that disallowances for delayed PF & ESI deposits, when made before the filing of the return of income, cannot be made under Section 43B or Section 36(1)(va) of the Income Tax Act. The Tribunal followed its earlier decisions on this issue.
The Tribunal found that the penalty was wrongly imposed as the assessee did not get adequate time to respond to the department's queries. Therefore, the penalty could not be upheld.
The Tribunal dismissed the appeal, holding that the assessee had consistently failed to provide explanations for the unexplained deposits and had abused the process of law. The delay condonation application was also rejected due to lack of merit and unsupported explanation.
The Tribunal held that the total withdrawals made by the assessee and his family members were sufficient to cover the rent payments and other household expenses. The pattern of petty withdrawals did not necessarily disprove the source of funds for the rent.
The Tribunal held that if employee contributions to ESI and PF are deposited after the due date under the respective Acts but before filing the return of income, they cannot be disallowed under Section 43B read with Section 36(1)(va) of the Income Tax Act.
The Tribunal found that the CIT(E) did not properly consider the submitted amended MOA and bye-laws and failed to examine the genuineness of the society's objectives. The CIT(E) also relied on irrelevant reasons for rejection.