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The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the assessee failed to discharge the onus of proving the creditworthiness of the shareholders and the genuineness of the transactions. The CIT(A) erred in deleting the addition solely based on banking channel transactions without proper substantiation.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the assessee would succeed on the issue of deduction under section 80IB(4) for the Jammu plant. It reasoned that the assessee was engaged in manufacturing, as evidenced by the blending process creating a saleable commodity distinct from raw materials, citing various High Court and Tribunal decisions, including those confirmed by the Supreme Court. The Tribunal distinguished unfavorable case laws relied upon by the revenue, finding them factually distinguishable. Regarding depreciation on UPS, the Tribunal directed the AO to rework it, considering UPS as an integral part of the computer system eligible for the same depreciation rate, or as electrical installations if used otherwise. For depreciation on electrical installations, the Tribunal dismissed the assessee's grounds, agreeing with the AO and DRP that they constitute electrical fittings and not Plant & Machinery. The appeal was thus partly allowed.
The Tribunal held that the CIT(A) provided multiple opportunities for submission, and the assessee's failure to comply justified the dismissal. The Tribunal also found no error in the CPC's processing under section 143(1) based on the provided audit report, thus no rectification under section 154 was warranted.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the AO failed in his duty to examine the claim of depreciation on artificially created goodwill and issue a notice under Section 142(1). Therefore, the assessment order was erroneous and prejudicial to the interest of revenue.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The Tribunal held that the levy of fees under Section 234E for processing returns filed prior to June 1, 2015, was not sustainable. However, for returns processed after June 1, 2015, the levy was upheld.
The ITAT admitted additional evidence filed by the assessee, which had a material bearing on the issue. The Tribunal directed the AO to examine these evidences and re-adjudicate the matter after providing an opportunity of hearing.
The Tribunal partly allowed the appeals. It deleted the interest disallowance under Section 14A, confirmed a portion of the disallowance related to average investment, and restored the issue of TDS on software payments to the Assessing Officer for verification.
The Tribunal held that the assessee failed to provide satisfactory explanations or evidence for the cash payment, nor did it fall under the exceptions of Rule 6DD. Therefore, the disallowance under Section 40A(3) was justified.
The Tribunal condoned the delay in filing the appeal before the CIT(A), noting that the period of delay fell within the exclusion period granted by the Supreme Court due to the pandemic. The case was remanded to the CIT(A) to decide on merits.
The Tribunal granted the assessee another opportunity to present their case, subject to a cost of Rs. 10,000 to be deposited with the Tamil Nadu State Legal Services Authority. The Assessing Officer is to re-adjudicate the issue on merits.
The Tribunal partly allowed the appeals. It deleted the interest disallowance under Section 14A, confirmed a portion of the disallowance related to average investment, and restored the issue of TDS on software payments to the Assessing Officer for verification.
The Tribunal held that the assessee failed to provide sufficient evidence to establish that the advance was given in the normal course of business or that it constituted a business loss. The advance was classified as an unsecured loan by the recipient company, and the write-off was based on the auditor's advice.
The Tribunal held that the CPC could not have made an adjustment disallowing the deduction under Section 80P while processing the return under Section 143(1) for the assessment year in question. This was because the specific enabling provision for such an adjustment, Section 143(1)(a)(v), did not cover Section 80P prior to its amendment by the Finance Act, 2021.
The Tribunal found that the assessee's non-compliance was due to Covid-19 infection and medical reasons, not intentional or willful. Considering the assessee's age, profession, and medical condition, the Tribunal deemed it not a fit case for penalty imposition.
The Tribunal directed the Assessing Officer to verify the assessee's claim regarding turnover. If the turnover is indeed below the prescribed limit, the penalty would not be sustainable.
The Tribunal, considering the principle of natural justice, decided to grant the assessee another opportunity to substantiate their claim. The matter was restored to the Assessing Officer for fresh consideration.
The Tribunal restored the matter back to the CIT(Exemption) to reconsider the application in light of the Supreme Court's decision in New Noble Education Society. The CIT(Exemption) is to decide the application afresh after considering the Supreme Court's guidelines.
The Tribunal held that the reasons provided by the assessee for the delay were vague and not bonafide. The Tribunal found no reasonable cause for the inordinate delay and thus rejected the condonation petition.
The Tribunal partly allowed the appeals. It deleted the interest disallowance under Section 14A, confirmed a portion of the disallowance related to average investment, and restored the issue of TDS on software payments to the Assessing Officer for verification.
The Tribunal allowed the Revenue's appeal regarding disallowance under Section 14A, but dismissed appeals related to book profit computation, 'provision no longer required' write-off, carbon credit treatment, and Section 80IA deduction.
The Tribunal noted a concurrent finding that the assessee failed to provide evidence for the cash payments. However, to provide an opportunity, the matter was remitted back to the Assessing Officer for re-adjudication.
The Tribunal held that interest disallowance to the extent of interest received from a partner on an amount transferred to him would not be sustainable. For the remaining disallowance, the assessee needs to demonstrate the business use of the bank loan.
The Tribunal held that the assessees had failed to substantiate the cost of improvement claims with documentary evidence. However, it allowed the Section 54 exemption, considering the Supreme Court's extension of limitation periods due to COVID-19, which covered the delay in property possession.
The Tribunal partially allowed the appeal, reducing the manufacturing loss addition to 7.5% and deleting the addition for excess stock. It held that the survey statement alone has no evidentiary value and the AO ignored the cost of stones and other metals in stock valuation.
The Tribunal held that the assessees had failed to substantiate the cost of improvement claims with documentary evidence. However, it allowed the Section 54 exemption, considering the Supreme Court's extension of limitation periods due to COVID-19, which covered the delay in property possession.
The Tribunal held that the penalty under Section 271(1)(c) is for failure to deduct TDS, not for belated remittance. Since the assessee had deducted the TDS, the penalty was deleted based on the Supreme Court's decision in US Technologies International Pvt. Ltd.
The Tribunal found that the CIT(A) failed to consider the assessee's detailed submissions and did not render independent findings. Therefore, the matter was set aside and restored to the CIT(A) for reconsideration.