ITAT Hyderabad Judgments — February 2023

The Tribunal upheld the method of estimating suppressed turnover but directed the Assessing Officer to determine profit at 12.5% of such turnover. Issues regarding undisclosed payments and cash found were restored to the Assessing Officer for fresh verification.

The Tribunal held that the payments made to contract teachers do not fall under the definition of 'fee for professional services' as defined in Section 194J and the relevant CBDT notifications. Therefore, TDS was not deductible under Section 194J.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the addition on account of tariff subsidy should be deleted if it's not a difference between sanctioned and paid amounts. The CSR expense issue was restored for verification. The consumer contribution amortization was restored for verification based on previous years' orders. The CIT(A)'s decision to allow carry forward of losses was upheld.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the amendment to Section 200A, which allowed for the computation and levy of late filing fees under Section 234E, was prospective. Therefore, late fees could not be charged for TDS statements relating to periods prior to June 1, 2015, even if the statements were filed late after that date.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal upheld the method of estimating suppressed turnover and directed the Assessing Officer to determine profit at 12.5% of the suppressed turnover. Issues regarding undisclosed payments and cash found were restored to the Assessing Officer for fresh verification.

The Tribunal upheld the method of estimating suppressed turnover and directed the Assessing Officer to determine profit at 12.5% of the suppressed turnover. Issues regarding undisclosed payments and cash found were restored to the Assessing Officer for fresh verification.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal restored the issue of deduction for electrical projects to the Assessing Officer for verification, following previous directions. It also directed the AO to allow enhanced deduction for electrical projects and upheld the CIT(A)'s decision on irrigation projects.

The Tribunal restored the issue of deduction for electrical projects to the Assessing Officer for verification, following previous directions. It also directed the AO to allow enhanced deduction for electrical projects and upheld the CIT(A)'s decision on irrigation projects.

The Tribunal restored the issue of deduction for electrical projects to the Assessing Officer for verification, following previous directions. It also directed the AO to allow enhanced deduction for electrical projects and upheld the CIT(A)'s decision on irrigation projects.

The Tribunal restored the issue of deduction for electrical projects to the Assessing Officer for verification, following previous directions. It also directed the AO to allow enhanced deduction for electrical projects and upheld the CIT(A)'s decision on irrigation projects.

The Tribunal restored the issue of deduction for electrical projects to the Assessing Officer for verification, following previous directions. It also directed the AO to allow enhanced deduction for electrical projects and upheld the CIT(A)'s decision on irrigation projects.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal found the 10% profit estimate arbitrary and unjustified, considering the assessee's accepted net profit of 3.03% in AY 2015-16 and the contractual margin. The commission was also considered subsumed within the business income.

The Tribunal held that since the section 263 orders were quashed by the ITAT, all consequential assessment orders based on them became infructuous. Therefore, the CIT(A) was correct in allowing the assessee's appeals.

The Tribunal held that since the section 263 orders were quashed by the ITAT, all consequential assessment orders based on them became infructuous. Therefore, the CIT(A) was correct in allowing the assessee's appeals.

The Tribunal held that the addition on account of tariff subsidy should be deleted if it's not a difference between sanctioned and paid amounts. The CSR expense issue was restored for verification. The consumer contribution amortization was restored for verification based on previous years' orders. The CIT(A)'s decision to allow carry forward of losses was upheld.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal held that the additions made by the AO were not sustainable. It found that the satisfaction note was not year-specific, the seized documents were 'dumb' without clear particulars, and evidence lacked the necessary Section 65B certificate for electronic records.

The Tribunal restored the issue of deduction for electrical projects to the Assessing Officer for verification, following previous directions. It also directed the AO to allow enhanced deduction for electrical projects and upheld the CIT(A)'s decision on irrigation projects.