ITAT Guwahati Judgments — September 2019

The Tribunal held that disallowance under Section 40(a)(ia) is not applicable if the recipient of the interest is exempt under Section 10(26). The Tribunal found no merit in the Revenue's reliance on a different High Court judgment.

The Tribunal held that the assessee is entitled to deductions under Section 80IE for its industrial undertakings. The Tribunal considered the provisions of Section 80IE and relevant case law regarding substantial expansion and the definition of 'initial assessment year'.

The Tribunal held that the assessee is entitled to deductions under Section 80IE for its industrial undertakings. The Tribunal considered the provisions of Section 80IE and relevant case law regarding substantial expansion and the definition of 'initial assessment year'.

The Tribunal held that the assessee is entitled to deductions under Section 80IE for its industrial undertakings. The Tribunal considered the provisions of Section 80IE and relevant case law regarding substantial expansion and the definition of 'initial assessment year'.

The Tribunal held that the assessee is entitled to deductions under Section 80IE for its industrial undertakings. The Tribunal considered the provisions of Section 80IE and relevant case law regarding substantial expansion and the definition of 'initial assessment year'.

The Tribunal held that the assessee is entitled to deductions under Section 80IE for its industrial undertakings. The Tribunal considered the provisions of Section 80IE and relevant case law regarding substantial expansion and the definition of 'initial assessment year'.

The Tribunal upheld the CIT(A)'s order on certain issues, dismissing some of the Revenue's appeals. For other grounds, the Tribunal directed the AO to recompute disallowances based on specific criteria, allowing some appeals for statistical purposes.

The Tribunal held that the assessee was deprived of an opportunity to pursue his lower appellate proceedings. Therefore, the appeal was restored for fresh adjudication.

The Tribunal partly allowed the appeal, deleting the addition related to M/s Chorus Machineries and allowing a portion of the unsecured loan. It also allowed a revised ad-hoc disallowance for other expenses and salary.

The Tribunal found no reason to interfere with the disallowances and additions made by the lower authorities. The assessee's failure to prove the source of deposits and non-deduction of TDS were key factors.

The Tribunal upheld the CIT(A)'s order on certain issues, dismissing some of the Revenue's appeals. For other grounds, the Tribunal directed the AO to recompute disallowances based on specific criteria, allowing some appeals for statistical purposes.

The Tribunal upheld the CIT(A)'s order on certain issues, dismissing some of the Revenue's appeals. For other grounds, the Tribunal directed the AO to recompute disallowances based on specific criteria, allowing some appeals for statistical purposes.

The Tribunal upheld the CIT(A)'s order on certain issues, dismissing some of the Revenue's appeals. For other grounds, the Tribunal directed the AO to recompute disallowances based on specific criteria, allowing some appeals for statistical purposes.

The Tribunal upheld the CIT(A)'s order on certain issues, dismissing some of the Revenue's appeals. For other grounds, the Tribunal directed the AO to recompute disallowances based on specific criteria, allowing some appeals for statistical purposes.

The Tribunal upheld the CIT(A)'s order on certain issues, dismissing some of the Revenue's appeals. For other grounds, the Tribunal directed the AO to recompute disallowances based on specific criteria, allowing some appeals for statistical purposes.

The Tribunal upheld the CIT(A)'s order on certain issues, dismissing some of the Revenue's appeals. For other grounds, the Tribunal directed the AO to recompute disallowances based on specific criteria, allowing some appeals for statistical purposes.

The Tribunal upheld the CIT(A)'s order on certain issues, dismissing some of the Revenue's appeals. For other grounds, the Tribunal directed the AO to recompute disallowances based on specific criteria, allowing some appeals for statistical purposes.

The Tribunal upheld the CIT(A)'s order on certain issues, dismissing some of the Revenue's appeals. For other grounds, the Tribunal directed the AO to recompute disallowances based on specific criteria, allowing some appeals for statistical purposes.

The Tribunal upheld the CIT(A)'s order on certain issues, dismissing some of the Revenue's appeals. For other grounds, the Tribunal directed the AO to recompute disallowances based on specific criteria, allowing some appeals for statistical purposes.

The Tribunal upheld the CIT(A)'s order on certain issues, dismissing some of the Revenue's appeals. For other grounds, the Tribunal directed the AO to recompute disallowances based on specific criteria, allowing some appeals for statistical purposes.

The Tribunal held that the addition of share capital was wrongly made as the assessee provided sufficient evidence and the reopening was based on an issue that was later settled by the Supreme Court. The Tribunal also directed the Assessing Officer to allow set off of disclosed income against undisclosed expenditure.

The Tribunal held that the addition of share capital was wrongly made as the assessee provided sufficient evidence and the reopening was based on an issue that was later settled by the Supreme Court. The Tribunal also directed the Assessing Officer to allow set off of disclosed income against undisclosed expenditure.

The Tribunal held that the addition of share capital was wrongly made as the assessee provided sufficient evidence and the reopening was based on an issue that was later settled by the Supreme Court. The Tribunal also directed the Assessing Officer to allow set off of disclosed income against undisclosed expenditure.

The Tribunal held that the addition of share capital was wrongly made as the assessee provided sufficient evidence and the reopening was based on an issue that was later settled by the Supreme Court. The Tribunal also directed the Assessing Officer to allow set off of disclosed income against undisclosed expenditure.

The Tribunal held that payments made to permit holders who act as government agents for the sale of IMFL, as per state excise rules, fall under the exceptions provided in Rule 6DD(b) and Rule 6DD(k) of the Income Tax Rules. Therefore, the disallowance under Section 40A(3) was not justified.

The Tribunal held that the addition of share capital was wrongly made as the assessee provided sufficient evidence and the reopening was based on an issue that was later settled by the Supreme Court. The Tribunal also directed the Assessing Officer to allow set off of disclosed income against undisclosed expenditure.

The Tribunal held that the addition of share capital was wrongly made as the assessee provided sufficient evidence and the reopening was based on an issue that was later settled by the Supreme Court. The Tribunal also directed the Assessing Officer to allow set off of disclosed income against undisclosed expenditure.

The Tribunal held that the addition of share capital was wrongly made as the assessee provided sufficient evidence and the reopening was based on an issue that was later settled by the Supreme Court. The Tribunal also directed the Assessing Officer to allow set off of disclosed income against undisclosed expenditure.

The Tribunal held that the addition of share capital was wrongly made as the assessee provided sufficient evidence and the reopening was based on an issue that was later settled by the Supreme Court. The Tribunal also directed the Assessing Officer to allow set off of disclosed income against undisclosed expenditure.

The Tribunal held that the assessee's books claiming the impugned expenditure deserved rejection for lack of evidence. However, the TDS disallowance was not pressed by the assessee.

The Tribunal held that the addition of share capital was wrongly made as the assessee provided sufficient evidence and the reopening was based on an issue that was later settled by the Supreme Court. The Tribunal also directed the Assessing Officer to allow set off of disclosed income against undisclosed expenditure.

The Tribunal held that the addition of share capital was wrongly made as the assessee provided sufficient evidence and the reopening was based on an issue that was later settled by the Supreme Court. The Tribunal also directed the Assessing Officer to allow set off of disclosed income against undisclosed expenditure.

The tribunal confirmed the levy of interest under section 234B, stating it is compensatory and automatic for non-payment of advance tax. However, it directed the AO to re-compute interest under section 234C based on the proviso allowing levy in subsequent installments for capital gains.