ITAT Delhi Judgments — April 2022

The Tribunal held that the disallowance of employee's contribution to PF/ESI on account of delayed deposit is not justified if the deposit is made before the filing of the return of income. The amendment by the Finance Act, 2021, which clarifies the disallowance, is not applicable to the assessment years under consideration.

The Tribunal held that the CIT(A) failed to follow the mandate of Section 250(6) of the IT Act by not deciding the appeals on merits and also violated the principles of natural justice by not providing sufficient opportunity of hearing.

The Tribunal held that the CIT(A) failed to follow the mandate of Section 250(6) of the IT Act by dismissing appeals without deciding on merits and also violated principles of natural justice. Therefore, the impugned orders were set aside.

The Tribunal held that the CIT(A) failed to follow the mandate of Section 250(6) of the IT Act by dismissing appeals without deciding on merits and also violated principles of natural justice. Therefore, the impugned orders were set aside.

The Tribunal held that the CIT(A) failed to follow the mandate of Section 250(6) of the IT Act by not deciding the appeals on merits and also violated the principles of natural justice by not providing sufficient opportunity of hearing.

The Tribunal held that the disallowance of employee's contribution to PF/ESI on account of delayed deposit is not justified if the deposit is made before the filing of the return of income. The amendment by the Finance Act, 2021, which clarified the disallowance, was held to be prospective and not applicable to the assessment years under consideration.

The Tribunal held that the disallowance of employee's contribution to PF/ESI on account of delayed deposit is not justified if the deposit is made before the filing of the return of income. The amendment by the Finance Act, 2021, which clarified the disallowance, was held to be prospective and not applicable to the assessment years under consideration.

The Tribunal noted that the dispute was settled under the Vivad Se Vishwas Scheme. Consequently, the appeal was dismissed with liberty to restore it if the settlement failed.

The Tribunal held that the support services were not ancillary to royalty income and did not 'make available' technical knowledge. Similarly, training expenses were found to be for orientation and did not involve transfer of technology, thus not qualifying as FIS.

The Tribunal held that the disallowance of employee's contribution to PF/ESI on account of delayed deposit is not justified if the deposit is made before the filing of the return of income. The amendment by the Finance Act, 2021, which clarified the disallowance, was held to be prospective and not applicable to the assessment years under consideration.

The Tribunal held that the CIT(A) failed to follow the mandate of Section 250(6) of the IT Act by not deciding the appeals on merits and also violated the principles of natural justice by not providing sufficient opportunity of hearing.

The Tribunal held that the disallowance of employee's contribution to PF/ESI on account of delayed deposit is not justified if the deposit is made before the filing of the return of income. The amendment by the Finance Act, 2021, which clarified the disallowance, was held to be prospective and not applicable to the assessment years under consideration.

The Tribunal held that the disallowance of employee's contribution to PF/ESI on account of delayed deposit is not justified if the deposit is made before the filing of the return of income. The amendment by the Finance Act, 2021, which clarified the disallowance, was held to be prospective and not applicable to the assessment years under consideration.

The Tribunal held that the disallowance of employee's contribution to PF/ESI on account of delayed deposit is not justified if the deposit is made before the filing of the return of income. The amendment by the Finance Act, 2021, which clarifies the disallowance, is not applicable to the assessment years under consideration.

The Tribunal held that the disallowance was not justified as the contributions were deposited before the return filing date. The amendment by the Finance Act, 2021, was held not applicable to the assessment years under consideration.

The Tribunal held that the disallowance of employee's contribution to PF/ESI on account of delayed deposit is not justified if the deposit is made before the filing of the return of income. The amendment by the Finance Act, 2021, which clarified the disallowance, was held to be prospective and not applicable to the assessment years under consideration.

The Tribunal held that the disallowance of employee's contribution to PF/ESI on account of delayed deposit is not justified if the deposit is made before the filing of the return of income. The amendment by the Finance Act, 2021, was held to be prospective and not applicable to the assessment years under consideration.

The Tribunal held that the disallowance of employee's contribution to PF/ESI on account of delayed deposit is not justified if the deposit is made before the filing of the return of income. The amendment by the Finance Act, 2021, which clarified the disallowance, was held to be prospective and not applicable to the assessment years under consideration.

The Tribunal held that the support services were not ancillary to royalty income and did not 'make available' technical knowledge. Similarly, training expenses were found to be for orientation and did not involve transfer of technology, thus not qualifying as FIS.

The Tribunal held that the CIT(A) failed to follow the mandate of Section 250(6) of the IT Act by dismissing appeals without deciding on merits and also violated principles of natural justice. Therefore, the impugned orders were set aside.

The Tribunal held that the disallowance of employee's contribution to PF/ESI on account of delayed deposit is not justified if the deposit is made before the filing of the return of income. The amendment by the Finance Act, 2021, which clarified the disallowance, was held to be prospective and not applicable to the assessment years under consideration.

The Tribunal held that the CIT(A) failed to follow the mandate of Section 250(6) of the IT Act by dismissing appeals without deciding on merits and also violated principles of natural justice. Therefore, the impugned orders were set aside.

The Tribunal held that the assessee's failure to produce books of account for the relevant assessment year, coupled with cash transactions and lack of documentary evidence, made the accounting of the sale proceeds doubtful. Therefore, the addition made by the Assessing Officer was confirmed.

The Tribunal held that tools, dies, and jigs are integral parts of the machinery used in manufacturing and therefore qualify as plant and machinery. The Tribunal also noted that the revenue had allowed similar claims in subsequent years for the assessee.

The Tribunal held that the disallowance of employee's contribution to PF/ESI on account of delayed deposit is not justified if the deposit is made before the filing of the return of income. The amendment by the Finance Act, 2021, which clarified the disallowance, was held to be prospective and not applicable to the assessment years under consideration.

The Tribunal held that the CIT(A) failed to follow the mandate of Section 250(6) of the IT Act by dismissing appeals without deciding on merits and also violated principles of natural justice. Therefore, the impugned orders were set aside.

The Tribunal held that the disallowance of employee's contribution to PF/ESI on account of delayed deposit is not justified if the deposit is made before the filing of the return of income. The amendment by the Finance Act, 2021, which clarified the disallowance, was held to be prospective and not applicable to the assessment years under consideration.

The Tribunal held that the disallowance of employee's contribution to PF/ESI on account of delayed deposit is not justified if the deposit is made before the filing of the return of income. The amendment by the Finance Act, 2021, which clarified the disallowance, was held to be prospective and not applicable to the assessment years under consideration.

The Tribunal dismissed the assessee's appeals as withdrawn, subject to the condition that if the dispute is not resolved under the VSV scheme, the assessee can seek reinstitution of the appeals.

The Tribunal held that the additions made by the Assessing Officer were not justified as the contributions were deposited before the filing of the return of income. The Tribunal followed the jurisdictional High Court's decision in CIT vs. AIMIL Ltd. and held that the amendment by Finance Act 2021 was not applicable to the assessment years under consideration.

The Tribunal held that the additions made by the Assessing Officer were not justified as the contributions were deposited before the filing of the return of income. The Tribunal followed the jurisdictional High Court's decision in CIT vs. AIMIL Ltd. and held that the amendment by Finance Act 2021 was not applicable to the assessment years under consideration.

The Tribunal held that the additions made by the Assessing Officer were not justified as the contributions were deposited before the filing of the return of income. The Tribunal followed the jurisdictional High Court's decision in CIT vs. AIMIL Ltd. and held that the amendment by Finance Act 2021 was not applicable to the assessment years under consideration.

The Tribunal held that the additions made by the Assessing Officer were not justified as the contributions were deposited before the filing of the return of income. The Tribunal followed the jurisdictional High Court's decision in CIT vs. AIMIL Ltd. and held that the amendment by Finance Act 2021 was not applicable to the assessment years under consideration.

The Tribunal held that the additions made by the Assessing Officer were not justified as the contributions were deposited before the filing of the return of income. The Tribunal followed the jurisdictional High Court's decision in CIT vs. AIMIL Ltd. and held that the amendment by Finance Act 2021 was not applicable to the assessment years under consideration.

The Tribunal held that the Assessing Officer should have allowed the exemption/deduction under Section 10 as claimed by the employer. The Tribunal also stated that the assessee is entitled to TDS credit as reflected in Form 26AS and must get any discrepancies rectified from the employer.

The Tribunal held that the additions made by the Assessing Officer were not justified as the contributions were deposited before the filing of the return of income. The Tribunal followed the jurisdictional High Court's decision in CIT vs. AIMIL Ltd. and held that the amendment by Finance Act 2021 was not applicable to the assessment years under consideration.

The Tribunal held that the additions made by the Assessing Officer were not justified as the contributions were deposited before the filing of the return of income. The Tribunal followed the jurisdictional High Court's decision in CIT vs. AIMIL Ltd. and held that the amendment by Finance Act 2021 was not applicable to the assessment years under consideration.

The Tribunal held that the additions made by the Assessing Officer were not justified as the contributions were deposited before the filing of the return of income. The Tribunal followed the jurisdictional High Court's decision in CIT vs. AIMIL Ltd. and held that the amendment by Finance Act 2021 was not applicable to the assessment years under consideration.

The Tribunal held that the additions made by the Assessing Officer were not justified as the contributions were deposited before the filing of the return of income. The Tribunal followed the jurisdictional High Court's decision in CIT vs. AIMIL Ltd. and held that the amendment by Finance Act 2021 was not applicable to the assessment years under consideration.

The Tribunal held that the additions made by the Assessing Officer were not justified as the contributions were deposited before the filing of the return of income. The Tribunal followed the jurisdictional High Court's decision in CIT vs. AIMIL Ltd. and held that the amendment by Finance Act 2021 was not applicable to the assessment years under consideration.

The Tribunal held that the additions made by the Assessing Officer were not justified as the contributions were deposited before the filing of the return of income. The Tribunal followed the jurisdictional High Court's decision in CIT vs. AIMIL Ltd. and held that the amendment by Finance Act 2021 was not applicable to the assessment years under consideration.

The Tribunal held that the additions made by the Assessing Officer were not justified as the contributions were deposited before the filing of the return of income. The Tribunal followed the jurisdictional High Court's decision in CIT vs. AIMIL Ltd. and held that the amendment by Finance Act 2021 was not applicable to the assessment years under consideration.

The Tribunal held that the additions made by the Assessing Officer were not justified as the contributions were deposited before the filing of the return of income. The Tribunal followed the jurisdictional High Court's decision in CIT vs. AIMIL Ltd. and held that the amendment by Finance Act 2021 was not applicable to the assessment years under consideration.

The Tribunal held that the additions made by the Assessing Officer were not justified as the contributions were deposited before the filing of the return of income. The Tribunal followed the jurisdictional High Court's decision in CIT vs. AIMIL Ltd. and held that the amendment by Finance Act 2021 was not applicable to the assessment years under consideration.

The Tribunal held that the additions made by the Assessing Officer were not justified as the contributions were deposited before the filing of the return of income. The Tribunal followed the jurisdictional High Court's decision in CIT vs. AIMIL Ltd. and held that the amendment by Finance Act 2021 was not applicable to the assessment years under consideration.

The Tribunal held that the additions made on account of delayed deposit of employee's contribution to PF and ESI were not justified. The amendment brought by Finance Act 2021 was not applicable to the assessment year under consideration.

The Tribunal held that the additions made by the Assessing Officer were not justified as the contributions were deposited before the filing of the return of income. The Tribunal followed the jurisdictional High Court's decision in CIT vs. AIMIL Ltd. and held that the amendment by Finance Act 2021 was not applicable to the assessment years under consideration.

The Tribunal held that the additions made by the Assessing Officer were not justified as the contributions were deposited before the filing of the return of income. The Tribunal followed the jurisdictional High Court's decision in CIT vs. AIMIL Ltd. and held that the amendment by Finance Act 2021 was not applicable to the assessment years under consideration.

The Tribunal held that the additions made on account of delayed deposit of employee's contribution to PF and ESI were not justified. The amendment brought by Finance Act 2021 was not applicable to the assessment year under consideration.

The Tribunal held that the addition made under Section 143(1) was beyond its scope as the issue was debatable and controversial, especially concerning the prospective or retrospective nature of amendments to Section 36(1)(va) and 43B. The jurisdictional High Court's precedents favored the assessee.