ITAT Delhi Judgments — February 2021

The Income Tax Appellate Tribunal (ITAT) allowed the assessee's request to withdraw the appeals. The tribunal noted that the settlement under the Vivad se Vishwas Scheme had been finalized.

The Income Tax Appellate Tribunal (ITAT) allowed the assessee's request to withdraw the appeals. The tribunal noted that the settlement under the Vivad se Vishwas Scheme had been finalized.

The Tribunal noted that the assessee had settled the dispute under the Vivad se Vishwas Act. Consequently, the appeal was treated as deemed to be withdrawn by the Revenue.

The tribunal noted that the assessee had settled the dispute under the Vivad se Vishwas Scheme and had been issued Form No. 3. Consequently, the assessee sought permission to withdraw the appeal.

The Tribunal held that without rejecting the books of accounts or pointing out specific discrepancies, the Assessing Officer should not have resorted to an ad hoc disallowance. Accounts regularly maintained and duly audited should be accepted unless there are adequate reasons to the contrary.

The assessee requested to withdraw the appeal as they had opted for the Vivad se Vishwas Scheme, 2020. The tribunal allowed the withdrawal.

The Tribunal decided to consign the appeal to records and treat it as dismissed, subject to the condition that if the dispute is not resolved under the Vivad se Vishwas Act, the assessee can seek reinstitution of the appeal.

The Tribunal held that the provisions of Section 195 of the Act were not applicable and that the disallowance made by the AO/DRP was not justified. The Tribunal deleted the addition, following its own previous decisions and decisions of coordinate benches on identical issues.

The Tribunal noted the assessee's request to withdraw the appeals due to opting for the Vivad Se Vishwas Scheme. The appeals were dismissed as withdrawn, with a liberty to approach the Tribunal for reinstitution if the settlement under the scheme is not resolved.

The Tribunal noted the assessee's decision to settle the dispute under the Vivad Se Vishwas Act and consequently consigned the appeals to records. The dismissal is subject to the condition that if the dispute is not resolved under the Act, the assessee can seek reinstitution of the appeals.

The Tribunal noted the assessee's decision to settle the dispute under the Vivad Se Vishwas Act. Consequently, the appeals were consigned to records and treated as dismissed.

The Tribunal noted the assessee's request to withdraw the appeals due to opting for the Vivad Se Vishwas Scheme. The appeals were dismissed as withdrawn, with a liberty to approach the Tribunal for reinstitution if the settlement under the scheme is not resolved.

The Tribunal held that the provisions of Section 195 of the Act were not applicable and that the disallowance made by the AO/DRP was not justified. The Tribunal deleted the addition, following its own previous decisions and decisions of coordinate benches on identical issues.

The Tribunal held that the assessee was eligible to invest Rs. 50,00,000/- in each financial year and claim exemption under Section 54EC for the assessment year 2014-15, as the amendment to limit investment to Rs. 50 lakh per financial year was prospective from AY 2015-16.

The assessee sought permission to withdraw the appeal after making the required payment and obtaining partial relief from the CIT(A). The Tribunal dismissed the appeal as withdrawn.

The tribunal accepted the assessee's request for withdrawal of the appeal. The appeal was dismissed as withdrawn.

The assessee sought permission to withdraw the appeal after paying the self-assessment tax and noting that the CIT(A) had already deleted a part of the addition. The tribunal granted permission to withdraw.

The Tribunal held that the international freight logistic support services and GAM expenses do not constitute managerial, consultancy, or technical services. Therefore, they do not fall under Section 9(1)(vii) of the Income Tax Act or Article 12 of the India-USA DTAA.

The Income Tax Appellate Tribunal (ITAT) allowed the assessee's request to withdraw the appeals. The tribunal noted that the settlement under the Vivad se Vishwas Scheme had been finalized.

The Tribunal accepted the assessee's request for withdrawal of the appeal. The appeal was dismissed as withdrawn based on the assessee's settlement under the Vivad Se Vishwas Scheme.

The Tribunal noted the assessee's request to withdraw the appeals due to opting for the Vivad Se Vishwas Scheme. The appeals were dismissed as withdrawn, with a liberty to approach the Tribunal for reinstitution if the settlement under the scheme is not resolved.

The tribunal noted that the assessee had opted to settle the issues under the Vivad se Vishwas Scheme, 2020. Consequently, the appeal was dismissed as withdrawn.

The Tribunal noted the assessee's intention to settle under the Vivad se Vishwas Act. The appeal was consigned to record and treated as dismissed for statistical purposes, with liberty to the assessee to seek reinstitution if the settlement fails.

The Tribunal accepted the assessee's request for withdrawal of the appeal. The appeal was dismissed as withdrawn by the Tribunal.

The Tribunal noted the assessee's request to withdraw the appeals due to opting for the Vivad Se Vishwas Scheme. The appeals were dismissed as withdrawn, with a liberty to approach the Tribunal for reinstitution if the settlement under the scheme is not resolved.

The tribunal allowed the assessee's request to withdraw the appeal. This was permitted because the assessee had opted to settle the issues under the Vivad se Vishwas Scheme, 2020.

The Tribunal decided to consign the appeal to record and treat it as dismissed, subject to the condition that if the dispute is not resolved under the Vivad Se Vishwas scheme, the assessee can seek reinstitution of the appeal.

The Tribunal noted the assessee's decision to settle under the Vivad se Vishwas Act and requested withdrawal of the appeal. The appeal was consigned to records and treated as dismissed.

The Tribunal noted the assessee's request to withdraw the appeals due to opting for the Vivad Se Vishwas Scheme. The appeals were dismissed as withdrawn, with a liberty to approach the Tribunal for reinstitution if the settlement under the scheme is not resolved.

The tribunal noted that upon filing the declaration under the Vivad Se Vishwas Act, any pending appeal is deemed to have been withdrawn. Consequently, both the Revenue's appeal and the Assessee's cross-appeal were dismissed as withdrawn.

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 appeal. The assessee had opted to settle the dispute under the Vivad Se Vishwas Scheme.

The tribunal accepted the assessee's request for withdrawal of the appeal. The appeal was dismissed as withdrawn.

The Tribunal held that the diary entries, when corroborated by bank statements and other evidence, represent real transactions and not mere estimates. It also found a business connection between the assessee and a housing society, suggesting involvement in their workings.

The Tribunal consigned the appeals to records and treated them as dismissed, subject to the condition that if the dispute is not resolved under the Vivad Se Vishwas Scheme, the parties can seek reinstitution of the appeals.

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 for withdrawal of the appeal. The appeal was dismissed as withdrawn.

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 for withdrawal of the appeal. The appeal was dismissed as withdrawn.

The Tribunal accepted the assessee's request to withdraw the appeal. The appeal was dismissed as withdrawn.

The Tribunal accepted the assessee's request for withdrawal of the appeals. The Senior DR had no objection to the withdrawal.

The Tribunal noted that the assessee had opted to settle the appeal under the Vivad Se Vishwas Scheme. Both parties agreed to treat the appeal as withdrawn.

The Tribunal noted that the assessee had opted to settle the appeals under the Vivad Se Vishwas Scheme, 2020. Both parties agreed that the appeals should be treated as withdrawn and dismissed as infructuous.

The Tribunal accepted the assessee's request for withdrawal of the appeal. The appeal was dismissed as withdrawn in light of the settlement under the Vivad Se Vishwas Scheme.

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 accepted the Assessee's request for dismissal of the Revenue's appeals due to the settlement under the Vivad Se Vishwas Scheme. The Assessee's cross-objection was dismissed as infructuous.

The Tribunal accepted the Assessee's request and dismissed the appeals filed by the Revenue. The Assessee's cross-objection was also dismissed as infructuous.

The tribunal accepted the assessee's request to withdraw the appeal. The appeal was dismissed as withdrawn.

The Tribunal accepted the Assessee's request and dismissed the appeals filed by the Revenue. The Assessee's cross-objection was also dismissed as infructuous.

The Tribunal permitted the assessee to withdraw the appeal. The appeal was dismissed as withdrawn, subject to the issuance of Form No.3.