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187 orders · Page 2 of 4
The Tribunal allowed the assessee's request to withdraw the appeal, as the respondent had no objection. The appeal was therefore dismissed as withdrawn.
The Tribunal allowed the assessee's request to withdraw the appeal. The Senior Departmental Representative did not object to this request.
The Tribunal condoned the delay in filing the appeals, accepting the assessee's explanation of non-communication. The appeals were set aside and remanded to the CIT(A) for disposal on merits.
The Tribunal condoned the delay in filing the appeals, accepting the assessee's explanation of non-communication. The appeals were set aside and remanded to the CIT(A) for disposal on merits.
The Tribunal condoned the delay in filing the appeals, accepting the assessee's explanation of non-communication. The appeals were set aside and remanded to the CIT(A) for disposal on merits.
The Tribunal condoned the delay in filing the appeals, accepting the assessee's explanation of non-communication. The appeals were set aside and remanded to the CIT(A) for disposal on merits.
The Tribunal held that in the absence of any incriminating material found during the search, no addition under Section 68 of the Act is warranted, following the decision in Kabul Chawla. Consequently, the assessee's appeals were allowed, and the Revenue's appeals were dismissed.
The Tribunal held that in the absence of any incriminating material found during the search, no addition under Section 68 of the Act is warranted, following the decision in Kabul Chawla. Consequently, the assessee's appeals were allowed, and the Revenue's appeals were dismissed.
The Tribunal considered the assessee's request for withdrawal and, with no objection from the Revenue, allowed the appeal to be withdrawn.
The Tribunal held that the issue of royalty payment adjustment has been settled by the competent authorities under the MAP. The agreed arm's length rates for royalty were 4% for AY 2014-15 and 3% for AY 2015-16.
The Tribunal held that the matter requires reconsideration as the CIT(E) did not discuss the details allegedly filed by the assessee. The impugned order did not clearly show that all submitted details were considered.
The Tribunal held that the matter requires reconsideration as the CIT(E) did not discuss the details allegedly filed by the assessee. The impugned order did not clearly show that all submitted details were considered.
The Tribunal held that the issue of royalty payment adjustment has been settled by the competent authorities under the MAP. The agreed arm's length rates for royalty were 4% for AY 2014-15 and 3% for AY 2015-16.
The Tribunal held that the written-off amount was a business loss due to non-recovery from the party and rightly adjusted. Regarding director's remuneration, the Tribunal found the amount paid to be reasonable considering the company's turnover and profit.
The Tribunal held that the Assessing Officer's rationale for disallowing the set-off was not statutorily tenable. It found that the computation of income filed by the assessee was correct as per the Income Tax Act, allowing the set-off of brought forward STCL.
The Tribunal directed the AO/TPO to recompute the ALP considering specific observations, including granting adjustment for idle capacity. The issue of deduction under Section 10A was restored to the AO for fresh examination.
The Tribunal upheld the CIT(A)'s decision to restrict the disallowance under Section 14A to a percentage of the average value of investments yielding exempt income. The order followed a Special Bench ruling on the issue.
The Tribunal upheld the principle that no disallowance under Section 14A is warranted if the assessee has not earned any exempt income. Consequently, the deletion of the disallowance by the CIT(A) was confirmed.
The Tribunal held that the CIT(A) did not properly consider the assessee's contentions and the AO's perspective. The Tribunal found a grey area regarding the CIT(A)'s reasoning and decided to allow additional evidence.
The Tribunal admitted additional evidence submitted by the assessee, citing reasons such as the death of the assessee's counsel and technological difficulties. The Tribunal found these documents crucial for a proper adjudication and restored the entire issue to the AO for fresh examination.
The Tribunal held that the assessee is not eligible for deduction under Section 80P(2)(a)(i) on interest earned from banks. However, it is eligible for deduction under Section 80P(2)(d) on interest earned from other cooperative societies. Expenses incurred in earning interest income taxable under 'income from other sources' are allowable under Section 57.
The Tribunal held that education cess and higher and secondary education cess are eligible for deduction while computing income chargeable under the head 'Profits and Gains of Business'. Relying on the Bombay High Court decision in Sesa Goa Ltd., the Tribunal directed the deletion of the disallowed amount.
The Tribunal admitted additional evidence submitted by the assessee, citing reasons such as the death of the assessee's counsel and technological difficulties. The Tribunal found these documents crucial for a proper adjudication and restored the entire issue to the AO for fresh examination.
The Tribunal held that the assessee is not eligible for deduction under Section 80P(2)(a)(i) on interest earned from banks. However, it is eligible for deduction under Section 80P(2)(d) on interest earned from other cooperative societies. Expenses incurred in earning interest income taxable under 'income from other sources' are allowable under Section 57.
The Tribunal noted that the issue regarding Section 14A disallowance was covered by previous orders in the assessee's own case. For the Section 80IA deduction, the Tribunal found that the Assessing Officer had rejected the claim prematurely without proper verification of the audited accounts.
The Tribunal held that the assessee is not eligible for deduction under Section 80P(2)(a)(i) on interest earned from banks. However, it is eligible for deduction under Section 80P(2)(d) on interest earned from other cooperative societies. Expenses incurred for earning interest income taxable under 'income from other sources' are allowable under Section 57.
The Tribunal held that the capital reserve created due to amalgamation, as per the High Court-approved scheme and accounting standards, could not be treated as a revaluation reserve. It also held that the short-term capital loss on mutual funds, disallowed under Section 94(7), is not an 'expenditure' relatable to exempt income under Section 115JB.
The tribunal accepted the assessee's request for withdrawal of the appeals. The appeals were dismissed as withdrawn by the tribunal.
The tribunal accepted the assessee's request to withdraw the appeals. The withdrawal was based on the assessee opting to settle the tax disputes under the Vivad Se Vishwas Scheme, 2020.
The tribunal accepted the assessee's request to withdraw the appeals. The withdrawal was based on the assessee opting to settle the tax disputes under the Vivad Se Vishwas Scheme, 2020.
The Income Tax Appellate Tribunal accepted the assessee's request for withdrawal of the appeal. The tribunal noted that a certificate under Section 5(1) of The Direct Tax Vivad Se Vishwas Act, 2020 was filed.
The Tribunal accepted the assessee's request for withdrawal of the appeal. The appeal was dismissed as withdrawn.
The tribunal accepted the assessee's request to withdraw the appeals. The withdrawal was based on the assessee opting to settle the tax disputes under the Vivad Se Vishwas Scheme, 2020.
The tribunal accepted the assessee's request to withdraw the appeal. The assessee had opted to settle the dispute under the Vivad Se Vishwas Scheme, 2020.
The Income Tax Appellate Tribunal accepted the assessee's request for withdrawal of the appeal. The tribunal noted that the assessee had opted to settle the dispute under The Direct Tax Vivad Se Vishwas Scheme, 2020.
The Tribunal accepted the assessee's request for withdrawal of the appeal. The appeal was dismissed as withdrawn in view of the settlement under the Vivad Se Vishwas Scheme.
The Tribunal considered the assessee's application for withdrawal of appeals. The Revenue had no objection to the withdrawal. Therefore, the Tribunal dismissed the appeals as withdrawn.
The Tribunal accepted the assessee's request to withdraw the appeal. The appeal was accordingly dismissed as withdrawn.
The Tribunal considered the application for withdrawal of appeals. Since the assessee accepted the Mutual Agreement Procedure (MAP) proceedings which had attained finality, the appeals were dismissed as withdrawn.
The Tribunal accepted the assessee's request for withdrawal of the appeal. The appeal was dismissed as withdrawn in view of the settlement under the Vivad Se Vishwas Scheme.
The Tribunal held that the AO exceeded his jurisdiction by making additions beyond the scope of the reasons recorded for initiating reassessment proceedings, especially when the original basis for reopening ceased to survive. Consequently, the penalty under Section 271(1)(c) was also set aside.
The Tribunal held that the AO exceeded his jurisdiction by making additions beyond the scope of the reasons recorded for initiating reassessment proceedings, especially when the original basis for reopening ceased to survive. Consequently, the penalty under Section 271(1)(c) was also set aside.
The Tribunal accepted the assessee's request for withdrawal of the appeals. The withdrawal was based on the assessee opting to settle the tax disputes under the Vivad Se Vishwas Scheme, 2020.
The Tribunal accepted the assessee's request for withdrawal of the appeals. This was based on the assessee opting to settle the tax disputes under the Vivad Se Vishwas Scheme, 2020.
The Income Tax Appellate Tribunal accepted the assessee's request for withdrawal of the appeal. The tribunal noted that the Senior DR had no objection to this request.
The Tribunal held that the CIT(A) should have decided the appeal on merits even if ex-parte, rather than dismissing it in limine. The first appellate order was set aside due to lack of reasoning and failure to consider the case on merits.
The tribunal accepted the assessee's request to withdraw the appeals. The withdrawal was based on the assessee opting to settle the tax disputes under the Vivad Se Vishwas Scheme, 2020.
The Tribunal accepted the assessee's request for withdrawal of the appeal. The appeal was dismissed as withdrawn based on the settlement under the Vivad Se Vishwas Scheme.
The Tribunal considered the assessee's application for withdrawal of appeals. The Revenue had no objection to the withdrawal. Therefore, the Tribunal dismissed the appeals as withdrawn.
The Tribunal held that the appeal filed by the Revenue was allowed for statistical purposes. The Cross Objection filed by the assessee was dismissed as it became academic in nature.