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The Tribunal held that the classification certificate, even if obtained in a subsequent year, is relevant for claiming deduction under Section 35AD. The conditions for a specified business under Section 35AD were fulfilled.
The Tribunal held that the classification certificate, even if obtained in a subsequent year, is relevant for claiming deduction under Section 35AD. The conditions for a specified business under Section 35AD were fulfilled.
The Tribunal held that the classification certificate, even if obtained in a subsequent year, is relevant for claiming deduction under Section 35AD. The conditions for a specified business under Section 35AD were fulfilled.
The Tribunal held that the assessee had provided sufficient documentation, including cash books and VAT returns, to support the cash sales. The Tribunal found no defects in the documentation or stock availability and concluded that the explanation for the cash deposits was genuine and reasonable.
The Tribunal upheld the CIT(A)'s deletion of the addition on unsecured loans, finding it was an old loan with repayments and no fresh loan was taken during the year. Similarly, the disallowance of interest on capital work-in-progress was deleted as no interest was charged on the NPA loan and thus not claimed by the assessee.
The Tribunal held that for penalty under Section 271AAA to be levied, the surrendered income must fall within the definition of 'undisclosed income' as per the explanation to the section. The onus is on the Assessing Officer to prove this with tangible material, which was not done in this case.
The tribunal held that the CIT(Exemptions) was justified in issuing a questionnaire to verify the genuineness of activities and compliance with the trust deed's objects. The assessee was directed to furnish the requested details.
The Tribunal found that the CIT(A)'s order was in breach of natural justice as the remand report was not disclosed to the assessee. Both parties agreed that the matter should be examined afresh by the Assessing Officer.
The tribunal held that merely uploading a notice on the Income Tax Portal does not constitute effective service. Therefore, the ex-parte order of the CIT(A) was unsustainable.
The Tribunal held that the CIT(A) erred in dismissing the appeals on limitation as the assessment order was not properly communicated and the appeal was filed within time after obtaining a certified copy. The principle of natural justice was also violated by not issuing a show-cause notice.
The Tribunal held that the assessee failed to comply with multiple notices issued by the Assessing Officer. Consequently, the assessment was completed under Section 144 based on available information.
The tribunal set aside the order of the CIT (Exemptions) and remanded the matter back for fresh adjudication. The CIT was directed to provide a reasonable opportunity to the assessee to present their case.
The Tribunal held that the CIT(A) erred in dismissing the appeals on limitation as the assessment order was not properly communicated and the appeal was filed within time after obtaining a certified copy. The principle of natural justice was also violated by not issuing a show-cause notice.
The tribunal dismissed the ground related to bonus disallowance as not pressed by the assessee. For the dividend income issue, the tribunal remanded the case back to the CIT(A) for verification by the Assessing Officer.
The Tribunal remanded the issue of ESI/PF disallowance to the CIT(A) for fresh adjudication in light of Supreme Court and ITAT rulings. For the bonus issue, the Tribunal directed the CIT(A) to verify the submitted documents and decide afresh, allowing the appeal for statistical purposes.
The Tribunal held that the assessee failed to comply with multiple notices issued by the Assessing Officer. Consequently, the assessment was completed under Section 144 based on available information.
The Tribunal directed the CIT(A) to admit and examine additional evidence submitted by the assessee regarding the cost of improvement, setting aside the matter for fresh adjudication.
The Tribunal held that merely uploading a notice on the Income Tax Portal does not constitute effective service of notice. The impugned orders were set aside, and the matter was remanded for fresh consideration.
The Tribunal held that the application filed was in substance a revised return under Section 139(5) and was filed within the stipulated time. It also noted that even if considered a rectification application, the CPC's failure to pass an order within six months would deem it accepted.
The Tribunal held that merely uploading a notice on the Income Tax Portal does not constitute effective service of notice. The impugned orders were set aside, and the matter was remanded for fresh consideration.
The Tribunal set aside the order of the CIT(A) and remanded the matter back for de novo proceedings. The assessee was directed to cooperate and produce all supporting documents for his defense.
The Tribunal found that the assessee's submissions were not considered by the CIT(A) before passing the order. Therefore, the appeals were set aside to the CIT(A) to decide afresh after providing a proper opportunity to the assessee.
The Tribunal upheld the decision of the lower authorities, stating that the assessee failed to provide sufficient evidence to substantiate its claims for TDS and TCS credit. The Tribunal found that the documents filed did not clearly reflect the claimed TDS and TCS amounts.
The Tribunal found that the lower authorities had not conducted sufficient inquiry and verification of the assessee's submissions, including ledger accounts of debtors and VAT returns. Therefore, the order of the CIT(A) was set aside.
The Tribunal held that the CIT(A) should have provided an opportunity to the assessee to explain the cash withdrawals before making adverse findings. The matter was set aside to the CIT(A) for re-examination of the cash withdrawal entries and their treatment in the books of account.
The Tribunal held that the Revenue's appeal was not maintainable due to the delay and the low tax effect involved, which did not fall under any exceptions to CBDT circulars. The appeal was dismissed on these grounds.
The Tribunal held that the amount of Rs. 3,39,29,643/- was already considered for addition in AY 2016-17 and confirmed by the CIT(A). Taxing the same amount again in AY 2017-18 would amount to double taxation, which is not permissible.
The Tribunal held that the assessee failed to comply with the conditions for claiming exemption under Section 11, specifically regarding the filing of Form 10B and the utilization of income for charitable purposes. Consequently, the exemption was rightly denied by the lower authorities.
The Tribunal held that the AO and CIT(A) should not have decided the case on an agreed basis without proper verification. The issue of disallowance of interest needs to be decided on merits after verifying the availability of own funds.
The Tribunal held that the assessee failed to comply with the conditions for claiming exemption under Section 11, specifically regarding the filing of Form 10B and the utilization of income for charitable purposes. Consequently, the exemption was rightly denied by the lower authorities.
The Tribunal held that once cash sales are accepted and tax on the profit from these sales is realized, the cash arising from these transactions cannot be disallowed and added back to the income. Doing so would amount to taxing the same income twice.
The Tribunal held that the addition could not be sustained as the assessee maintained audited books of accounts, sales were supported by VAT declarations, and the AO's inquiry was not confronted to the assessee. It was also noted that adding sales realization as unexplained cash credit would amount to double taxation.
The Tribunal decided that the transfer pricing adjustment for Corporate Service Fee should be allowed, but restricted to 50% of the benefit received from financial services. For interest expenses on capital expansion, the matter was remitted back to the AO for verification of loan utilization.
The assessee requested to withdraw the appeal because they had received the approval under Section 80G(5) via Form 10AC. The revenue did not object to the withdrawal.
The Tribunal held that once the purchases and stock of the assessee were accepted, and the books of account were not rejected, there was no reason to deny the sales made out of such stock. The Tribunal also noted that accepting cash sales and then adding the same cash deposited in the bank would amount to double taxation.
The Tribunal held that the Assessing Officer had duly considered the surrendered income and explained its source as business income. The PCIT's view that the income should be taxed under Section 115BBE was not sustainable as the AO had applied his mind and the source of income was adequately explained.
The Tribunal held that filing the return of income within the time allowed under Section 139, including belatedly under Section 139(4), satisfies the condition under Section 12A(1)(ba). Therefore, the exemption under Section 11 cannot be denied solely on account of a belatedly filed return.
The Tribunal held that principles of natural justice require proper opportunity of hearing. It set aside the CIT(A)'s ex-parte order and remanded the matter for fresh adjudication after giving the assessee an adequate opportunity to present its case.
The Tribunal restored the appeals to the Assessing Officer for recalculating taxes, treating the Assessee as an Association of Persons (AOP). The Assessing Officer was directed not to make fresh assessments but to adjudicate old issues if required due to the changed status.
The Tribunal restored the appeals to the Assessing Officer for recalculating taxes, treating the Assessee as an Association of Persons (AOP). The Assessing Officer was directed not to make fresh assessments but to adjudicate old issues if required due to the changed status.
The Tribunal restored the appeals to the Assessing Officer for recalculating taxes, treating the Assessee as an Association of Persons (AOP). The Assessing Officer was directed not to make fresh assessments but to adjudicate old issues if required due to the changed status.
The Tribunal restored the appeals to the Assessing Officer for recalculating taxes, treating the Assessee as an Association of Persons (AOP). The Assessing Officer was directed not to make fresh assessments but to adjudicate old issues if required due to the changed status.
The Tribunal held that Section 145A contemplates valuation of inventory at the lower of actual cost or net realizable value, and taxes/duties are not includible in closing work in progress if not actually paid. The issue was covered by previous decisions in the assessee's own case.
The Tribunal noted that the CIT(A) order was ex-parte as notices were sent only on the income-tax portal, which the assessee did not see in time. Following the jurisdictional High Court's decision, the matter was remitted back to the CIT(A) for fresh adjudication.
The Tribunal held that a statement recorded during a search cannot be the sole basis for an addition without any incriminating documentary evidence. Relying on Supreme Court and ITAT precedents, the addition was deemed unsustainable.
The Tribunal held that merely uploading notices on the e-portal does not constitute effective service. The principles of natural justice require proper and adequate opportunity for the assessee to present their case.
The Tribunal held that notices on the e-portal alone are not sufficient for communication, and principles of natural justice require an opportunity of being heard. The case was restored to the CIT(A) for a fresh decision.
The Tribunal held that the PCIT erred in assuming jurisdiction under Section 263 as the AO had applied his independent mind and taken a possible view. The Tribunal found that the AO had considered the assessee's submissions and evidence before passing the assessment order.
The Tribunal held that since the assessee's appeals for the same assessment years were previously allowed by quashing the assessment orders due to reopening under Section 148 being bad in law, nothing further survives for adjudication in the Revenue's appeals.
The Tribunal held that notices issued on the ITBA portal without proper communication, as per Section 282(1) and Rule 127(1), violate principles of natural justice. Therefore, the matter was restored to the Assessing Officer for a fresh decision.