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1,092 orders · Page 7 of 22
The Tribunal restored the issue to the AO, granting the assessee one final opportunity to substantiate the source of the cash deposits. The previous orders of the AO and CIT(A) were set aside pending this re-examination.
The Tribunal admitted an additional ground raised by the assessee concerning the treatment of exempted excise duty. However, as this issue was raised for the first time, it was remanded to the AO/TPO for fresh adjudication.
The Tribunal allowed the withdrawal of the appeal as the assessee had opted for the Vivad Se Vishwas Scheme. The appeal was dismissed with liberty to restore it if the dispute settlement failed.
The assessee requested withdrawal of the appeal as they opted to settle the dispute under the Vivad Se Vishwas Scheme, 2020. The tribunal accepted the withdrawal request.
The Tribunal condoned the delay in filing the appeal, acknowledging the circumstances beyond the assessee's control. The ex parte order of the CIT(A) was set aside, and the appeal was remanded for fresh disposal.
The Tribunal dismissed the assessee's appeal as withdrawn, subject to the condition that if the dispute is not resolved under the VSV scheme, the assessee can seek reinstitution of the appeal.
The tribunal allowed the assessee's request to withdraw the appeal. This was based on the assessee opting to settle the dispute under the Vivad Se Vishwas scheme.
The Tribunal restored the issue to the AO, directing him to grant one final opportunity to the assessee to substantiate the source of the cash deposit. The assessee is also directed to appear before the AO and present evidence.
The Tribunal dismissed the appeal as withdrawn based on the assessee's request to settle the dispute under the Vivad Se Vishwas Scheme. The assessee reserved the right to seek reinstitution of the appeal if the settlement is not resolved.
The Tribunal found merit in the assessee's argument that the method of maintaining books of accounts was consistent and that the expenses claimed were reasonable and comparable to previous years. The Tribunal also noted that a coordinate bench had deleted similar disallowances for a sister concern.
The Tribunal held that since the assessee had not earned any dividend income, the provisions of Section 14A were not applicable. The appeal was allowed based on this finding.
The tribunal deleted the disallowance under Section 14A as it was made without jurisdiction in a limited scrutiny case. The disallowance of car running expenses was also deleted as the revenue failed to prove the personal nature of the expenses.
The Tribunal admitted an additional ground raised by the assessee concerning the treatment of exempted excise duty. However, as this issue was raised for the first time, it was remanded to the AO/TPO for fresh adjudication.
The Tribunal held that the appeal did not fall under the exceptions listed in the CBDT circulars. Since the tax effect was below the enhanced monetary limit and no exceptional circumstances applied, the appeal was not maintainable.
The Tribunal noted the assessee's request for withdrawal of the appeal due to opting for the Vivad Se Vishwas Scheme. The appeal was dismissed as withdrawn, with a liberty to seek reinstitution if the settlement under the scheme is not resolved.
The Tribunal allowed the assessee's request to withdraw the appeal. This was based on the assessee opting to settle the dispute under the Vivad Se Vishwas scheme.
The Tribunal dismissed the assessee's appeal as withdrawn, subject to the condition that if the dispute is not resolved under the Vivad se Vishwash Act, the assessee can seek reinstitution of the appeal.
The Tribunal admitted an additional ground raised by the assessee concerning the treatment of exempted excise duty. However, as this issue was raised for the first time, it was remanded to the AO/TPO for fresh adjudication.
The Tribunal admitted an additional ground raised by the assessee concerning the treatment of exempted excise duty. However, as this issue was raised for the first time, it was remanded to the AO/TPO for fresh adjudication.
The Tribunal upheld the CIT(A)'s decision to delete the additions. It found that no incriminating material was found during the search for the relevant assessment year, making the assessment under Section 153A unsustainable.
The Tribunal decided to consign the appeals to records and treat them as dismissed, subject to the condition that the assessee can seek reinstitution if the dispute is not resolved under the Vivad Se Vishwas Scheme.
The Tribunal accepted the assessee's request for withdrawal of the appeals. The Senior DR had no objection to this request.
The Tribunal dismissed the assessee's appeal as withdrawn, subject to the condition that if the dispute is not resolved under the VSV scheme, the assessee can seek reinstitution of the appeal.
The Tribunal decided to consign the appeals to records and treat them as dismissed, subject to the condition that the assessee can seek reinstitution if the dispute is not resolved under the Vivad Se Vishwas Scheme.
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 assessee requested withdrawal of the appeal as they opted to settle the tax arrears under the Vivad Se Vishwas Scheme, 2020. The Tribunal accepted this request.
The Tribunal restored all appeals to the file of the CIT(A) for fresh adjudication. This was done to ensure substantial justice, with a direction for the assessees to cooperate fully.
The Tribunal restored all appeals to the file of the CIT(A) for fresh adjudication. This was done to ensure substantial justice, with a direction for the assessees to cooperate fully.
The Tribunal restored all appeals to the file of the CIT(A) for fresh adjudication. This was done to ensure substantial justice, with a direction for the assessees to cooperate fully.
The Tribunal accepted the assessee's request for withdrawal of the appeals. The Senior DR had no objection to this request.
The Tribunal restored all appeals to the file of the CIT(A) for fresh adjudication. This was done to ensure substantial justice, with a direction for the assessees to cooperate fully.
The Tribunal held that the interest income should be assessed under the head 'Profits & Gains of Business or Profession'. This decision was based on the principle of consistency and previous favorable rulings for the assessee.
The tribunal accepted the assessee's request for withdrawal of the appeal. The assessee had opted to settle the tax arrears under the Vivad Se Vishwas Scheme.
The tribunal accepted the assessee's request for withdrawal of the appeals. The appeals were dismissed as withdrawn.
The Tribunal restored all appeals to the file of the CIT(A) for fresh adjudication. This was done to ensure substantial justice, with a direction for the assessees to cooperate fully.
The Tribunal held that since the Indian subsidiary (RIPL) was already remunerated at arm's length, no further attribution of profit to the PE was warranted. Even when deducting the remuneration paid to RIPL from the attributed profits, no taxable income remained.
The tribunal accepted the assessee's request for withdrawal of the appeal. This was based on the assessee opting to settle the tax arrears under the Vivad Se Vishwas Scheme, 2020.
The Tribunal held that for assessment year 2013-14, the assessee was eligible to claim set-off of loss against income determined under Section 115BBE, as the amendment disallowing set-off was prospective. Consequently, the revenue's appeal was dismissed.
The tribunal noted the assessee's decision to opt for the Vivad se Vishwas scheme. Consequently, the appeal was rendered infructuous.
The assessee requested to withdraw the appeal as they opted to settle the tax arrears under the Vivad Se Vishwas Scheme, 2020. The Tribunal accepted this request.
The Tribunal accepted the assessee's request for withdrawal of the appeal. The appeal was dismissed as withdrawn.
The Tribunal dismissed the Revenue's appeals concerning the classification of sales tax and central excise subsidies as revenue receipts. The Tribunal also partly allowed the assessee's appeals on certain issues, while restoring others to the Assessing Officer for fresh adjudication.
The Tribunal noted that the assessee had opted for the Vivad se Vishwas scheme. Therefore, the appeal was dismissed as infructuous.
The Tribunal upheld the CIT(A)'s decision, stating that similar royalty disallowances were previously decided in favor of the assessee by the ITAT and High Court. For commission payments, the Tribunal found that the foreign agents did not render technical services in India, thus Section 9(1)(vii)(b) was not applicable.
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 dismissed the Revenue's appeals concerning the classification of sales tax and central excise subsidies as revenue receipts. The Tribunal also partly allowed the assessee's appeals on certain issues, while restoring others to the Assessing Officer for fresh adjudication.
The Tribunal dismissed the Revenue's appeals concerning the classification of sales tax and central excise subsidies as revenue receipts. The Tribunal also partly allowed the assessee's appeals on certain issues, while restoring others to the Assessing Officer for fresh adjudication.
The tribunal accepted the assessee's request to withdraw the appeal. This was due to the assessee opting to settle the tax arrears under the Vivad Se Vishwas Scheme, 2020.
The Tribunal restored all appeals to the file of the CIT(A) for fresh adjudication. This was done to ensure substantial justice, with a direction for the assessees to cooperate fully.
The tribunal accepted the assessee's request for withdrawal. The appeal was dismissed as withdrawn.