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496 orders · Page 8 of 10
The Tribunal accepted the assessee's request for withdrawal of the appeals. Consequently, all appeals filed by the assessee were dismissed as withdrawn.
The Tribunal accepted the assessee's request for withdrawal of the appeals. Consequently, all appeals filed by the assessee were dismissed as withdrawn.
The Tribunal accepted the assessee's request for withdrawal of the appeals. Consequently, all appeals filed by the assessee were dismissed as withdrawn.
The Tribunal accepted the assessee's request for withdrawal of the appeals. Consequently, all appeals filed by the assessee were dismissed as withdrawn.
The Tribunal accepted the assessee's request for withdrawal of the appeals. Consequently, all appeals filed by the assessee were dismissed as withdrawn.
The Tribunal accepted the assessee's request for withdrawal of the appeals. Consequently, all appeals filed by the assessee were dismissed as withdrawn.
The Tribunal held that the addition made on account of interest on PDCs was not supported by any corroborative evidence found during the searches. Furthermore, the penalty was bad in law as the Assessing Officer did not specify the limb of Section 271(1)(c) in the notice, and the penalty did not survive as the quantum appeal was decided in favour of the assessee.
The Tribunal accepted the assessee's request for withdrawal of the appeal. The appeal was dismissed as withdrawn.
The Tribunal held that the assessee had provided sufficient evidence, including PAN, ITR, RBI registration, audited accounts, and bank statements of the investor companies, to establish their identity, creditworthiness, and the genuineness of the transactions. The AO's addition was therefore deleted.
The assessee requested withdrawal of the appeal as they opted to settle the dispute under the 'Vivad Se Vishwas Scheme, 2020'. The Revenue had no objection to this request.
The Tribunal held that the appeal was not maintainable as the tax effect was below the monetary limit prescribed by CBDT Circulars. The appeal was dismissed on this ground.
The Tribunal followed a coordinate bench's order, which had deleted additions on account of foreign bank accounts, and thus upheld the deletion of interest income and the consequential penalty.
The Tribunal held that the CIT(A) order was ex-parte and the assessee was not given adequate opportunity of hearing. Therefore, in the interest of justice, the matter was remanded back to the CIT(A) for proper adjudication of all issues after giving the assessee a proper hearing.
The Tribunal followed a coordinate bench's order, which had deleted additions on account of foreign bank accounts, and thus upheld the deletion of interest income and the consequential penalty.
The Tribunal treated the appeal 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 accepted the assessee's request for withdrawal of the appeal. The appeal was dismissed as withdrawn.
The Tribunal found that the CIT(A) dismissed the appeal without giving the assessee an adequate opportunity to present its case. Therefore, the matter was restored to the CIT(A) for a decision on merits after granting one final opportunity.
The Tribunal admitted the additional ground as it involved a pure question of law with facts on record. Following its own earlier decisions, the Tribunal held that lease premium charges qualify as an intangible asset eligible for depreciation under Section 32(1)(ii) of the Act.
The tribunal noted that the appeal had become infructuous due to the assessee opting for the Vivad Se Vishwas Scheme. Consequently, the appeal was treated as withdrawn and dismissed.
The Tribunal noted that the tax effect of the appeal was below the threshold limit set by CBDT circulars for filing appeals. The Revenue's counsel agreed that the appeal was not maintainable and did not press the appeal.
The Tribunal upheld the CIT(A)'s deletion of disallowance of export commission, holding that running royalty payments are not capital expenditure. It also upheld the deletion of warranty provision disallowance, noting that the issue was decided in favour of the assessee in previous years.
The Tribunal acknowledged the assessee's request for withdrawal due to opting for the Vivad Se Vishwas Scheme. The appeal was consigned to records and treated as dismissed, with a caveat for reinstitution if the settlement fails.
The Tribunal held that the addition made on account of interest on PDCs was not supported by any corroborative evidence found during the searches. Furthermore, the penalty was bad in law as the Assessing Officer did not specify the limb of Section 271(1)(c) in the notice, and the penalty did not survive as the quantum appeal was decided in favour of the assessee.
The Tribunal upheld the CIT(A)'s deletion of disallowance of export commission, holding that running royalty payments are not capital expenditure. It also upheld the deletion of warranty provision disallowance, noting that the issue was decided in favour of the assessee in previous years.
The Tribunal held that the reassessment proceedings under Section 147 were not sustainable as there was no whisper in the recorded reasons indicating any omission or failure on the part of the assessee in disclosing material facts. Consequently, the grounds on merits became academic.
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 accordingly dismissed as withdrawn.
The Tribunal accepted the assessee's request for withdrawal of the appeal. The appeal was dismissed as withdrawn.
The Tribunal held that interest received on compensation for land acquisition is a capital receipt and not taxable as income unless specifically provided for. The CIT(A) failed to consider relevant Supreme Court judgments.
The Tribunal acknowledged the assessee's decision to settle the dispute under the Vivad Se Vishwas Scheme. The appeal was consigned to records and treated as dismissed, with a caveat for reinstitution if the settlement fails.
The Tribunal held that the Department's appeal was not maintainable due to revised monetary limits for filing appeals as per CBDT Circular No.17/2019. The assessee also did not press their cross objections.
The Tribunal accepted the assessee's request for withdrawal of the appeal. The appeal was dismissed as withdrawn.
The Tribunal held that the addition was an ad-hoc estimation based on an average gross profit rate and not directly related to any undisclosed income unearthed during the search. The assessee's explanation for the stock discrepancy due to software malfunction was given credence.
The Tribunal held that the appeals of the Revenue deserved to be dismissed on account of low tax effect, as per CBDT Circular No. 17/2019 and its subsequent clarification. The appeals were dismissed without going into the merits of the case.
The Tribunal held that the appeals of the Revenue deserved to be dismissed on account of low tax effect, as per CBDT Circular No. 17/2019 and its subsequent clarification. The appeals were dismissed without going into the merits of the case.
The Tribunal held that the penalty notice and the assessment order were vague as they did not specify under which limb of Section 271(1)(c) the penalty was initiated. Following various High Court and Supreme Court decisions, the penalty was deemed unsustainable.
The Tribunal noted that the assessees sought to withdraw their appeals due to opting for the VSV scheme, and the Revenue had no objection. The appeals were dismissed as withdrawn.
The Tribunal dismissed the appeal as withdrawn, 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 allowed the assessee's request to withdraw the appeal. The department had no objection to the withdrawal.
The Tribunal upheld the CIT(A)'s order, noting that the assessee, a public sector undertaking, had consistently claimed such expenses which were accepted in earlier years. The CIT(A) found the AO's disallowance to be ad hoc and not based on specific defects, and that sufficient documents were provided by the assessee.
The Tribunal held that the AO could not make additions under Section 153A for non-abated years without incriminating material found during the search. The CIT(A) had correctly deleted the addition after examining the evidence provided by the assessee, which the Revenue failed to rebut.
The Tribunal accepted the assessee's request for withdrawal of the appeal. The appeal was dismissed as withdrawn.
The Tribunal held that no proceedings can continue against the corporate debtor (assessee) due to the insolvency proceedings. Section 238 of the Code overrides other statutes, including the Income-tax Act, and all claims must be dealt with under the Code.
The Tribunal held that no proceedings can continue against the corporate debtor (assessee) due to the insolvency proceedings. Section 238 of the Code overrides other statutes, including the Income-tax Act, and all claims must be dealt with under the Code.
The Tribunal noted the assessee's application to withdraw the appeal. Consequently, the appeal was dismissed as withdrawn.
The Tribunal held that no proceedings can continue against the corporate debtor (assessee) due to the insolvency proceedings. Section 238 of the Code overrides other statutes, including the Income-tax Act, and all claims must be dealt with under the Code.
The Tribunal held that no proceedings can continue against the corporate debtor (assessee) due to the insolvency proceedings. Section 238 of the Code overrides other statutes, including the Income-tax Act.
The Tribunal held that no proceedings can continue against the corporate debtor (assessee) due to the insolvency proceedings. Section 238 of the Code overrides other statutes, including the Income-tax Act.
The Tribunal dismissed the revenue's appeal. This was because the assessee had entered into an Advance Pricing Agreement (APA) which covered the impugned assessment year, and the revised return and Form 3CEF were accepted by the AO.