87 orders · Page 1 of 2
The Tribunal held that the CIT(A)'s rejection of the assessee's books of account and estimation of income at 30% was not acceptable. The Tribunal found that the additions made by the Assessing Officer related to unaccounted income found during the search and were not a basis for rejecting the books of account.
The Tribunal held that the CIT(A)'s rejection of the assessee's books of account and estimation of income at 30% was not acceptable. The Tribunal found that the additions made by the Assessing Officer related to unaccounted income found during the search and were not a basis for rejecting the books of account.
The Tribunal held that the CIT(A)'s rejection of the assessee's books of account and estimation of income at 30% was not acceptable. The Tribunal found that the additions made by the Assessing Officer related to unaccounted income found during the search and were not a basis for rejecting the books of account.
The Tribunal held that the CIT(A)'s rejection of the assessee's books of account and estimation of income at 30% was not acceptable. The Tribunal found that the additions made by the Assessing Officer related to unaccounted income found during the search and were not a basis for rejecting the books of account.
The Tribunal noted that the assessee had filed two appeals against the same order due to a numbering mistake. To avoid redundancy, the Tribunal dismissed the current appeal.
The Tribunal condoned the delay in filing the appeal due to the assessee's age and lack of resources. Considering the documents produced by the assessee to explain the source of deposits, the Tribunal set aside the orders of the authorities below and restored the issue to the Assessing Officer for verification.
The Tribunal held that the partition decree was a process of adjusting equities and not a simple acquisition of shares. Therefore, the entire capital gains should be treated as long-term capital gains.
The Tribunal held that the AO had misinterpreted the DRP's direction and incorrectly computed the capital gains. The Tribunal directed the AO to reduce the sale consideration by the indexed cost of acquisition. The issue regarding Section 54F deduction and credit of taxes paid was restored to the AO for further consideration.
The Tribunal held that the CIT(A)'s rejection of the assessee's books of account and estimation of income at 30% was not acceptable. The Tribunal found that the additions made by the Assessing Officer related to unaccounted income found during the search and were not a basis for rejecting the books of account.
The Tribunal upheld the CIT(A)'s deletion of additions related to the cost of construction and the deduction under Section 54GB. The decision was based on the principle of consistency with the assessee's wife's case and reliance on Supreme Court and Tribunal precedents.
The Tribunal held that an assessment order passed in disregard to the directions of the DRP is without jurisdiction and void. Following High Court judgments, the impugned order was quashed.
The Tribunal held that the CIT(A)'s rejection of the assessee's books of account and estimation of income at 30% was not acceptable. The Tribunal found that the additions made by the Assessing Officer related to unaccounted income found during the search and were not a basis for rejecting the books of account.
The Tribunal held that the CIT(A)'s rejection of the assessee's books of account and estimation of income at 30% was not acceptable. The Tribunal found that the additions made by the Assessing Officer related to unaccounted income found during the search and were not a basis for rejecting the books of account.
The Tribunal held that the CIT(A)'s rejection of the assessee's books of account and estimation of income at 30% was not acceptable. The Tribunal found that the additions made by the Assessing Officer related to unaccounted income found during the search and were not a basis for rejecting the books of account.
The Tribunal held that the CIT(A)'s rejection of the assessee's books of account and estimation of income at 30% was not acceptable. The Tribunal found that the additions made by the Assessing Officer related to unaccounted income found during the search and were not a basis for rejecting the books of account.
The Tribunal held that the CIT(A)'s rejection of the assessee's books of account and estimation of income at 30% was not acceptable. The Tribunal found that the additions made by the Assessing Officer related to unaccounted income found during the search and were not a basis for rejecting the books of account.
The Tribunal held that the CIT(A)'s rejection of the assessee's books of account and estimation of income at 30% was not acceptable. The Tribunal found that the additions made by the Assessing Officer related to unaccounted income found during the search and were not a basis for rejecting the books of account.
The Tribunal held that the CIT(A)'s rejection of the assessee's books of account and estimation of income at 30% was not acceptable. The Tribunal found that the additions made by the Assessing Officer related to unaccounted income found during the search and were not a basis for rejecting the books of account.
The Tribunal held that the CIT(A)'s rejection of the assessee's books of account and estimation of income at 30% was not acceptable. The Tribunal found that the additions made by the Assessing Officer related to unaccounted income found during the search and were not a basis for rejecting the books of account.
The Tribunal held that the CIT(A)'s rejection of the assessee's books of account and estimation of income at 30% was not acceptable. The Tribunal found that the additions made by the Assessing Officer related to unaccounted income found during the search and were not a basis for rejecting the books of account.
The Tribunal held that the CIT(A)'s rejection of the assessee's books of account and estimation of income at 30% was not acceptable. The Tribunal found that the additions made by the Assessing Officer related to unaccounted income found during the search and were not a basis for rejecting the books of account.
The Tribunal held that the CIT(A)'s rejection of the assessee's books of account and estimation of income at 30% was not acceptable. The Tribunal found that the additions made by the Assessing Officer related to unaccounted income found during the search and were not a basis for rejecting the books of account.
The Tribunal held that the CBDT Circular No. 17/2019, which enhanced the monetary limit for filing appeals, is applicable to pending appeals. Since the tax effect in this appeal was below the prescribed limit, the appeal was not maintainable.
The Tribunal noted that the assessee was subsequently granted new registration under Section 12A for the relevant assessment year. Therefore, the matter was restored to the CIT(A) for fresh consideration in light of the new registration.
The Tribunal held that a statement recorded under section 132(4) cannot be used in assessment proceedings unless it is supported by cogent incriminating material found during the search. Since no such material was found, the addition made by the Assessing Officer was deleted.
The Tribunal held that if the original shares were acquired through foreign exchange, then bonus shares allotted subsequently are also considered foreign exchange assets. The Tribunal followed its previous decision in the assessee's husband's case with identical facts.
The Tribunal held that the period of six assessment years preceding the relevant assessment year for section 153C is to be reckoned from the date of the search in the case of the person searched, as per the Supreme Court's decision in CIT vs. Jasjit Singh. Therefore, the assessment for AY 2017-18 under section 153C was valid.
The Tribunal upheld the CIT(A)'s deletion, stating that the payee had declared the income and paid taxes. It noted that as of the decision date, the Delhi High Court's ruling was still valid and no contrary view from the Apex Court existed.
The Tribunal dismissed the issue of interest on receivables as not pressed. It restored the issues of ITES and management fee to the AO/TPO for re-examination based on specific arguments regarding comparability and cost-to-cost arrangements. The issue of ad-hoc disallowance of foreign outward remittances was also restored for further consideration.
The assessee requested to withdraw the appeals before the ITAT to comply with the High Court's order. The Revenue had no objection.
The Tribunal held that the re-assessment proceedings were valid. It directed the AO to recalculate the capital gains by considering the actual transferable land area and the appropriate guideline value.
The assessee requested to withdraw the appeals before the ITAT to comply with the High Court's order. The Revenue had no objection.
The tribunal allowed the assessee's request to withdraw the appeal. The appeal was dismissed as withdrawn.
The Tribunal held that the re-assessment proceedings were valid. It directed the AO to recalculate the capital gains by considering the actual transferable land area and the appropriate guideline value.
The Tribunal held that since the assessee declared the amount as business income and the accounting year was not closed at the time of the search, Section 69A read with Section 115BBE was not applicable. The additional income should be taxed under normal provisions of the Act.
The Tribunal held that while the genuineness of the expenditure was questionable due to lack of proper documentation and related party transactions, the expenditure was incurred for business operations. Therefore, a portion of the expenditure was disallowed to meet the ends of justice.
The Tribunal held that additions made by the Assessing Officer were not based on incriminating material found during the search. Relying on previous decisions and Supreme Court pronouncements, the Tribunal dismissed the Revenue's appeals.
The Tribunal held that additions made by the Assessing Officer were not based on incriminating material found during the search. Relying on previous decisions and Supreme Court pronouncements, the Tribunal dismissed the Revenue's appeals.
The Tribunal held that additions made by the Assessing Officer were not based on incriminating material found during the search. Relying on previous decisions and Supreme Court pronouncements, the Tribunal dismissed the Revenue's appeals.
The Tribunal held that additions made by the Assessing Officer were not based on incriminating material found during the search. Relying on previous decisions and Supreme Court pronouncements, the Tribunal dismissed the Revenue's appeals.
The Tribunal held that additions made by the Assessing Officer were not based on incriminating material found during the search. Relying on previous decisions and Supreme Court pronouncements, the Tribunal dismissed the Revenue's appeals.
The Tribunal held that additions made by the Assessing Officer were not based on incriminating material found during the search. Relying on previous decisions and Supreme Court pronouncements, the Tribunal dismissed the Revenue's appeals.
The Tribunal held that additions made by the Assessing Officer were not based on incriminating material found during the search. Relying on previous decisions and Supreme Court pronouncements, the Tribunal dismissed the Revenue's appeals.
The Tribunal held that additions made by the Assessing Officer were not based on incriminating material found during the search. Relying on previous decisions and Supreme Court pronouncements, the Tribunal dismissed the Revenue's appeals.
The Tribunal held that in the absence of any incriminating material found during the search, concluded assessments cannot be disturbed under Section 153A. The Supreme Court decision in PCIT vs. Abhisar Buildwell P. Ltd. was relied upon.
The Tribunal held that additions made by the Assessing Officer were not based on incriminating material found during the search. Relying on previous decisions and Supreme Court pronouncements, the Tribunal dismissed the Revenue's appeals.
The Tribunal held that additions made by the Assessing Officer were not based on incriminating material found during the search. Citing previous judgments and a Supreme Court decision, the Tribunal dismissed the appeals filed by the Revenue.
The Tribunal dismissed the appeals filed by the Revenue, holding that no additions were made based on incriminating material found during the search. The Tribunal also dismissed the assessees' appeals as infructuous, following its decision on the Revenue's appeals.
The Tribunal held that in the absence of any incriminating material found during the search, concluded assessments cannot be disturbed under Section 153A. The Supreme Court decision in PCIT vs. Abhisar Buildwell P. Ltd. was relied upon.
The Tribunal held that in the absence of any incriminating material found during the search, concluded assessments cannot be disturbed under Section 153A. The Supreme Court decision in PCIT vs. Abhisar Buildwell P. Ltd. was relied upon.