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155 orders · Page 1 of 4
The Tribunal held that the purchase of land for development as inventory is a business activity itself and not an extension of business. Therefore, the proviso to Section 36(1)(iii) does not apply, and the interest paid on the loan for acquiring inventory is allowable as a deduction.
The Tribunal held that the lease rental agreement was genuine and the lease deposit was for business purposes. Therefore, the interest paid on loans borrowed for business could not be disallowed simply because rental payments had not yet commenced.
The Tribunal upheld the CIT(A)'s decision on all grounds. It ruled that no disallowance under Section 14A is warranted if no exempt income is earned, and that forward contract losses for hedging currency fluctuations are not speculative. The Tribunal also found that disallowance of stitching charges solely for non-production of the party was unjustified when other evidence was provided.
The Tribunal held that additions made in an unabated assessment without incriminating material are not sustainable. However, interest income directly linked to undisclosed loan transactions found during search is taxable.
The Tribunal held that the AO and CIT(A) erred in estimating making charges based on assumed wastage without sufficient evidence. Since the assessee neither debited nor credited these charges, Section 40(a)(ia) was not applicable.
The Tribunal permitted the assessee to withdraw the appeal as they had opted for the Vivad-se-Vishwas Scheme. The assessee was also informed that they could approach the Tribunal if any injustice occurred regarding the settlement.
The Tribunal permitted the assessee to withdraw the appeal as they had opted for the Vivad-se-Vishwas Scheme and were awaiting the issuance of Form No. 3. The assessee was given liberty to approach the Tribunal if any injustice occurred.
The Tribunal permitted the assessee to withdraw the appeal as she had opted for the Vivad-se-Vishwas Scheme. The assessee was also informed that she could approach the Tribunal if any injustice occurred regarding the scheme settlement.
The Tribunal dismissed the appeals as withdrawn, allowing liberty to restore them if the 'Vivad se Vishwas Scheme' application is rejected. The consequences of opting out or misrepresentation under the scheme were also clarified.
The Tribunal dismissed the appeals as withdrawn, allowing liberty to restore them if the 'Vivad se Vishwas Scheme' application is rejected. The consequences of opting out or misrepresentation under the scheme were also clarified.
The Tribunal dismissed the appeals as withdrawn, allowing liberty to restore them if the 'Vivad se Vishwas Scheme' application is rejected. The consequences of opting out or misrepresentation under the scheme were also clarified.
The Tribunal dismissed the appeals as withdrawn, allowing liberty to restore them if the 'Vivad se Vishwas Scheme' application is rejected. The consequences of opting out or misrepresentation under the scheme were also clarified.
The Tribunal dismissed the appeals as withdrawn, allowing the assessees to utilize the Vivad se Vishwas Scheme. Liberty was granted to restore the appeals if their applications under the scheme were rejected.
The Tribunal dismissed the appeals as withdrawn, allowing liberty to restore them if the application under the Vivad se Vishwas Scheme is rejected. It also clarified the revival of proceedings if the assessee opts out or misrepresents facts.
The Tribunal dismissed the appeals as withdrawn, allowing liberty to restore them if the application under the Vivad se Vishwas Scheme is rejected. It also clarified the revival of proceedings if the assessee opts out or misrepresents facts.
The Tribunal dismissed the appeals as withdrawn, allowing liberty to restore them if the application under the Vivad se Vishwas Scheme is rejected. It also clarified the revival of proceedings if the assessee opts out or misrepresents facts.
The Tribunal dismissed the appeals as withdrawn, allowing the assessees to utilize the Vivad se Vishwas Scheme. Liberty was granted to restore the appeals if their applications under the scheme were rejected.
The Tribunal dismissed the appeals as withdrawn, allowing liberty to restore them if the application under the Vivad se Vishwas Scheme is rejected. It also clarified the revival of proceedings if the assessee opts out or misrepresents facts.
The Tribunal dismissed the appeals as withdrawn, allowing the assesses to utilize the Vivad se Vishwas Scheme. Liberty was granted to restore the appeals if the scheme application was rejected.
The Tribunal dismissed the appeals as withdrawn, allowing the assesses to utilize the Vivad se Vishwas Scheme. Liberty was granted to restore the appeals if the scheme application was rejected.
The Tribunal dismissed the appeals as withdrawn, allowing the assesses to utilize the Vivad se Vishwas Scheme. Liberty was granted to restore the appeals if the scheme application was rejected.
The Tribunal permitted the assessee to withdraw the appeal as they had opted for the Vivad-se-Vishwas Scheme. The assessee can approach the Tribunal if any injustice arises from the scheme settlement.
The Tribunal permitted the assessee to withdraw the appeal as they had opted for the Vivad-se-Vishwas Scheme. The assessee can approach the Tribunal if any injustice arises from the scheme settlement.
The Tribunal permitted the assessee to withdraw the appeal as they had opted for the Vivad-se-Vishwas Scheme. The assessee can approach the Tribunal if any injustice arises from the settlement.
The Tribunal permitted the assessee to withdraw the appeals as they have opted for the Vivad-se-Vishwas Scheme. The assessee can approach the Tribunal if any injustice arises from the scheme settlement.
The Tribunal, following the decision of the Madras High Court, dismissed the appeals as withdrawn, allowing liberty to restore them if the Vivad se Vishwas scheme application is rejected.
The Tribunal noted that the Vivad se Vishwas Scheme allows for the settlement of direct tax disputes. Following a similar High Court decision, the Tribunal dismissed the appeals as withdrawn.
The Tribunal noted that the Vivad se Vishwas Scheme allows for the settlement of direct tax disputes. Following a similar High Court decision, the Tribunal dismissed the appeals as withdrawn.
The Tribunal permitted the assessee to withdraw the appeals as they have opted for the Vivad-se-Vishwas Scheme. The assessee can approach the Tribunal if any injustice arises from the scheme's settlement.
The Tribunal found that while the assessee claimed to have provided explanations and reconciliation, the authorities below were not convinced. The Tribunal decided to set aside the appeal to the Assessing Officer for reconsideration.
The Tribunal found that the Assessing Officer accepted the assessee was not a member of the AOP but still relied on the survey report for the AOP. The Tribunal held that the nature of income from lands sold individually should be independently examined without influence from the AOP's survey.
The Tribunal held that the additions made by the Assessing Officer were not sufficient to warrant the levy of penalty under Section 271(1)(c). The assessee had provided evidence, and mere disallowances or claims not fully substantiated to the AO's satisfaction do not automatically imply concealment of income.
The Tribunal held that payments for independent professional services rendered outside India by entities without a permanent establishment in India are not taxable in India and thus not subject to TDS under Section 195. For internet and professional charges, the Tribunal remanded the issue to the AO to verify if TDS was deducted before the due date of filing the return.
The Tribunal agreed with both parties to set aside the appeal to the Assessing Officer. The Assessing Officer is directed to reconsider the disallowance of discount after examining the evidence and to refer the property valuation to the DVO for capital gains computation.
The Tribunal found that the Assessing Officer accepted the assessee was not a member of the AOP but still relied on the survey report for the AOP. The Tribunal held that the nature of income from lands sold individually should be independently examined without influence from the AOP's survey.
The Tribunal held that while a nexus between expenditure and business operations is essential for deduction, genuine expenses incurred for maintaining business continuity during a temporary lull should be considered. The issue was remanded to the AO for re-examination of the expenditure's nature and necessity.
The Tribunal permitted the assessees to withdraw their appeals. It was noted that the assessees could approach the Tribunal again if any injustice arose from the Vivad-se-Vishwas settlement.
The Tribunal dismissed the appeals as withdrawn, allowing the assessees to utilize the Vivad se Vishwas Scheme. Liberty was granted to restore the appeals if the scheme application is rejected.
The Tribunal dismissed the appeals as withdrawn, allowing the assessees to utilize the Vivad se Vishwas Scheme. Liberty was granted to restore the appeals if the scheme application is rejected.
The Tribunal dismissed the appeals as withdrawn, allowing the assessees to utilize the Vivad se Vishwas Scheme. Liberty was granted to restore the appeals if the scheme application is rejected.
The Tribunal dismissed the appeals as withdrawn, allowing the assessees to utilize the Vivad se Vishwas Scheme. Liberty was granted to restore the appeals if the scheme application is rejected.
The Tribunal dismissed the appeals as withdrawn, allowing the assessees to utilize the Vivad se Vishwas Scheme. Liberty was granted to restore the appeals if the scheme application is rejected.
The Tribunal dismissed the appeals as withdrawn, allowing the assessees to utilize the Vivad se Vishwas Scheme. Liberty was granted to restore the appeals if the scheme application is rejected.
The Tribunal dismissed the appeals as withdrawn, allowing the assessees to utilize the Vivad se Vishwas Scheme. Liberty was granted to restore the appeals if the scheme application is rejected.
The Tribunal permitted the assessee to withdraw the appeal as they had opted for the Vivad-se-Vishwas Scheme. The assessee retains the right to approach the Tribunal if any injustice arises from the scheme's settlement.
The Tribunal dismissed the appeals as withdrawn, allowing the assessees to utilize the Vivad se Vishwas Scheme. Liberty was granted to restore the appeals if the scheme application is rejected.
The Tribunal permitted the assessees to withdraw their appeals. It was noted that the assessees could approach the Tribunal again if any injustice arose from the Vivad-se-Vishwas settlement.
The Tribunal permitted the assessee to withdraw the appeal. It was clarified that the assessee could approach the Tribunal again if any injustice arose from the Vivad-se-Vishwas settlement.
The Tribunal permitted the assessee to withdraw the appeal as they had opted for the Vivad-se-Vishwas Scheme. The assessee can approach the Tribunal again if any injustice arises from the settlement.
The Tribunal permitted the assessee to withdraw the appeal as they had opted for the Vivad-se-Vishwas Scheme. The assessee can approach the Tribunal if any injustice arises from the scheme's settlement.