808 orders · Page 5 of 17
The Tribunal held that the appeals were not maintainable as the tax effect involved was less than Rs. 20,00,000, as per CBDT Circular No. 03 of 2018. The Revenue could not demonstrate that any appeal fell under the exceptional categories for contestation.
The Tribunal held that the appeals were not maintainable as the tax effect involved was less than Rs. 20,00,000, as per CBDT Circular No. 03 of 2018. The Revenue could not demonstrate that any appeal fell under the exceptional categories for contestation.
The Tribunal held that the appeals were not maintainable due to the low tax effect, as per the CBDT circular. The Revenue was directed to withdraw or not press such appeals.
The Tribunal held that the appeals were not maintainable as the tax effect involved was less than Rs. 20,00,000, as per CBDT Circular No. 03 of 2018. The Revenue could not demonstrate that any appeal fell under the exceptional categories for contestation.
The Tribunal held that the appeals were not maintainable as the tax effect involved was less than Rs. 20,00,000, as per CBDT Circular No. 03 of 2018. The Revenue could not demonstrate that any appeal fell under the exceptional categories for contestation.
The Tribunal held that all appeals filed by the Revenue were not maintainable as the tax effect involved was less than Rs. 20,00,000/-, as per CBDT Circular No. 03 of 2018. Cross objections filed by assessees were either dismissed as not pressed or became infructuous.
The Tribunal held that the appeals were not maintainable as the tax effect involved was less than Rs. 20,00,000, as per CBDT Circular No. 03 of 2018. The Revenue could not demonstrate that any appeal fell under the exceptional categories for contestation.
The Tribunal held that the appeals were not maintainable due to the low tax effect, as per the CBDT circular. The Revenue was directed to withdraw or not press such appeals.
The Tribunal held that the appeals were not maintainable as the tax effect involved was less than Rs. 20,00,000, as per CBDT Circular No. 03 of 2018. The Revenue could not demonstrate that any appeal fell under the exceptional categories for contestation.
The Tribunal held that all appeals filed by the Revenue were not maintainable as the tax effect was less than Rs. 20,00,000/-, as per CBDT Circular No. 03 of 2018. Cross objections filed by assessees were either dismissed as not pressed or became infructuous.
The Tribunal dismissed all three appeals filed by the Revenue. This decision was based on the CBDT Circular No. 3 of 2018, which mandates dismissal of appeals with a tax effect below Rs. 20 lakhs.
The Tribunal held that the appeals were not maintainable due to the low tax effect, as per the CBDT circular. The Revenue was directed to withdraw or not press such appeals.
The Tribunal held that the appeals were not maintainable as the tax effect involved was less than Rs. 20,00,000, as per CBDT Circular No. 03 of 2018. The Revenue could not demonstrate that any appeal fell under the exceptional categories for contestation.
The Tribunal held that the appeals were not maintainable due to the low tax effect, as per the CBDT circular. The Revenue was directed to withdraw or not press such appeals.
The Tribunal held that the appeals were not maintainable due to the low tax effect, as per the CBDT circular. The Revenue was directed to withdraw or not press such appeals.
The Tribunal held that the appeals were not maintainable as the tax effect involved was less than Rs. 20,00,000, as per CBDT Circular No. 03 of 2018. The Revenue could not demonstrate that any appeal fell under the exceptional categories for contestation.
The Tribunal held that the appeals were not maintainable due to the low tax effect, as per the CBDT circular. The Revenue was directed to withdraw or not press such appeals.
The Tribunal held that the appeals were not maintainable as the tax effect involved was less than Rs. 20,00,000, as per CBDT Circular No. 03 of 2018. The Revenue could not demonstrate that any appeal fell under the exceptional categories for contestation.
The Tribunal held that the appeals were not maintainable as the tax effect involved was less than Rs. 20,00,000, as per CBDT Circular No. 03 of 2018. The Revenue could not demonstrate that any appeal fell under the exceptional categories for contestation.
The Tribunal held that the AO/TPO cannot decide on the commercial expediency of incurring an expense. The TPO's determination of the arm's length price at nil was not supported by any established transfer pricing method and was factually incorrect, as the assessee did receive valuable technical know-how.
The Tribunal, following the ratio of the Bombay High Court in B.R. Bamsi vs. CIT, held that the revenue's appeals contesting the deletion of additions made by the AO should be dismissed. The assessee's defensive plea to maintain the status quo, without seeking additional relief, was accepted.
The Tribunal held that the CIT(A)'s reasoning for allowing depreciation in earlier years was sound, as even passive use of assets entitles depreciation. The Tribunal found no difference in facts from earlier years and reversed the CIT(A)'s order for the current year.
The Tribunal, following the ratio of the Bombay High Court in B.R. Bamsi vs. CIT, held that the revenue's appeals contesting the deletion of additions made by the AO should be dismissed. The assessee's defensive plea to maintain the status quo, without seeking additional relief, was accepted.
The Tribunal held that the appeals were not maintainable due to the low tax effect, as per the CBDT circular which was applicable retrospectively. The Revenue could not demonstrate that any of the appeals fell under the exceptions for contesting appeals despite low tax effect.
The Tribunal held that the issue of transfer pricing adjustment for delayed receivables requires re-examination by the AO/TPO in light of the Delhi High Court's ruling in Principal CIT vs. Kusum Health Care Pvt. Ltd. The Tribunal also upheld the deletion of depreciation disallowance, following the Supreme Court's decision in ICDS Ltd. vs. CIT.
The Tribunal held that grounds related to the confirmation of the addition under Section 14A were covered by its earlier decision in the assessee's own case and were dismissed. However, a dispute regarding the computation of investment amounts for Rule 8D calculation was remanded back to the Assessing Officer.
The Tribunal held that the payments made to Dr. Thiele and Dr. Werner Stibal were for independent scientific services and fell under Article 14 of the respective DTAAs. Consequently, these payments were not chargeable to tax in India, and no tax deduction at source was required.
The Tribunal held that the appeals were not maintainable due to the low tax effect, as per the CBDT circular which was applicable retrospectively. The Revenue could not demonstrate that any of the appeals fell under the exceptions for contesting appeals despite low tax effect.
The Tribunal partly allowed the appeal. It confirmed the addition of Rs. 1,29,15,000/- on account of unexplained cash deposits. However, it deleted an addition of Rs. 5,15,000/- related to property valuation, confirming the balance addition of Rs. 21 lakhs.
The Tribunal held that in terms of CBDT Circular No. 3/2018 and Section 268A of the Income Tax Act, the appeal should not have been pressed by the Revenue. Therefore, the appeal was dismissed in limine.
The Tribunal noted that a coordinate bench had already decided this issue in favor of the assessee in the bank's own case. Therefore, the appeal filed by the AO was dismissed.
The Tribunal held that the appeals were not maintainable due to the low tax effect, as per the CBDT circular which was applicable retrospectively. The Revenue could not demonstrate that any of the appeals fell under the exceptions for contesting appeals despite low tax effect.
The Tribunal held that the income shown as capital gains should be treated as such, not business income, and allowed the benefit of indexation. It also directed the deletion of the disallowance made under Section 14A due to lack of proper satisfaction recorded by the Assessing Officer.
The Tribunal held that the appeals were not maintainable due to the low tax effect, as per the CBDT circular which was applicable retrospectively. The Revenue could not demonstrate that any of the appeals fell under the exceptions for contesting appeals despite low tax effect.
The Tribunal held that in terms of CBDT Circular No. 3/2018 and Section 268A of the Income Tax Act, the appeal by the Revenue should not have been pressed. Therefore, the appeal was dismissed in limine.
The Tribunal held that the share transactions were a sham and a colorable device to avoid capital gains tax, setting aside the CIT(A)'s order. The AO's disallowance was restored.
The Tribunal held that in terms of CBDT Circular No. 3/2018, the appeal should not have been pressed by the Revenue. Consequently, the appeal was dismissed in limine.
The Tribunal held that the appeals were not maintainable due to the low tax effect, as per the CBDT circular which was applicable retrospectively. The Revenue could not demonstrate that any of the appeals fell under the exceptions for contesting appeals despite low tax effect.
The Tribunal held that the Pr. CIT rightly invoked Section 263 as the AO failed to conduct proper enquiry and verification regarding the 'suspense account'. The Tribunal agreed that the assessment order was erroneous and prejudicial to the revenue due to this lack of verification.
The Tribunal held that the transactions were a camouflage for loans to avoid the provisions of Section 2(22)(e). The Tribunal found that the alleged agreement to sell and its cancellation lacked genuineness and were not supported by adequate evidence.
The Tribunal held that the Pr. CIT rightly invoked Section 263 as the AO failed to conduct proper enquiry and verification regarding the 'suspense account'. The Tribunal agreed that the assessment order was erroneous and prejudicial to the revenue due to this lack of verification.
The Tribunal held that the department's appeal was not maintainable as it was filed against the CBDT circular's monetary limit. The assessee's cross-objections were dismissed as they supported the CIT(A)'s order and sought no specific relief.
The Tribunal held that the Pr. CIT rightly invoked Section 263 as the AO failed to conduct proper enquiry and verification regarding the 'suspense account'. The Tribunal agreed that the assessment order was erroneous and prejudicial to the revenue due to this lack of verification.
The Tribunal held that the Pr. CIT rightly invoked Section 263 as the AO failed to conduct proper enquiry and verification regarding the 'suspense account'. The Tribunal agreed that the assessment order was erroneous and prejudicial to the revenue due to this lack of verification.