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168 orders · Page 4 of 4
The Tribunal held that the amendment to Section 115BBG, which treats carbon credits as revenue, is applicable only from AY 2018-19 onwards. For AY 2014-15, carbon credit receipts are considered capital receipts, not taxable as revenue, based on High Court decisions.
The Tribunal held that Section 14A is not applicable to banking companies as their shares and securities are stock-in-trade. The Tribunal also directed the AO to delete additions made towards disallowance under Section 14A.
The Tribunal upheld the DRP's decision that the management services were not sufficiently evidenced, thus confirming the disallowance of management fees paid to the AE. The Tribunal also upheld the disallowance of the grossed-up portion of TDS on external commercial borrowings, finding the assessee's procedure contrary to the agreement and law.
The Tribunal restored the matter to the Assessing Officer to examine the assessee's claim for exemption under Section 10(23C)(iiiad) as an educational institution. The assessee was given an opportunity to substantiate its claim.
The Tribunal upheld the DRP's decision that the management services were not sufficiently evidenced, thus confirming the disallowance of management fees paid to the AE. The Tribunal also upheld the disallowance of the grossed-up portion of TDS on external commercial borrowings, finding the assessee's procedure contrary to the agreement and law.
The Tribunal held that the CIT(A) should have disposed of the appeal on merits after providing a reasonable opportunity of hearing. The assessee's appeal was allowed for statistical purposes, remanding the matter back to the CIT(A).
The Tribunal held that the lease income should be treated as business income, considering the assessee's business-like exploitation of the property and its real estate development interests, aligning with Supreme Court precedents.
The Tribunal held that the transaction was a purchase of a capital asset at a negotiated price and not a business transaction. Therefore, the addition under Section 28(iv) was not justified as it was not a benefit or perquisite arising from the assessee's business.
The Tribunal noted that no enhancement notice was issued by the CIT(Appeals) and granted the assessee another opportunity to substantiate the source of the cash deposits. The matter was restored to the Assessing Officer for de-novo assessment.
The Tribunal held that the lease income should be treated as business income, considering the assessee's business-like exploitation of the property and its real estate development interests, aligning with Supreme Court precedents.
The Tribunal held that Section 14A is not applicable to banking companies as their shares and securities are stock-in-trade. The Tribunal also directed the AO to delete additions made towards disallowance under Section 14A.
The Tribunal found that the principles of natural justice were violated by the Assessing Officer and the CIT(A)'s order was non-speaking. Therefore, the lower authorities' orders were set aside and the matter was remanded back to the Assessing Officer for fresh adjudication.
The Tribunal held that the lease income should be treated as business income, considering the assessee's business-like exploitation of the property and its real estate development interests, aligning with Supreme Court precedents.
The Tribunal held that Section 14A is not applicable to banking companies as their shares and securities are stock-in-trade. The Tribunal also directed the AO to delete additions made towards disallowance under Section 14A.
The Tribunal condoned the delay in filing the appeal before the CIT(A), noting that the initial manual filing was due to a misunderstanding of e-filing rules. The CIT(A) was directed to admit the appeal and adjudicate on merits.
The Tribunal dismissed the appeals as withdrawn based on the assessee's request and the issuance of Form 3 under the Vivad se Vishwas Scheme. Liberty was granted to restore the appeals if the application before the Designated Authority is rejected.
The Tribunal dismissed the appeals as withdrawn based on the assessee's request and the issuance of Form 3 under the Vivad se Vishwas Scheme. Liberty was granted to restore the appeals if the application before the Designated Authority is rejected.
The Tribunal dismissed the appeals as withdrawn based on the assessee's request and the issuance of Form 3 under the Vivad se Vishwas Scheme. Liberty was granted to restore the appeals if the application before the Designated Authority is rejected.