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807 orders · Page 8 of 17
The Tribunal dismissed the appeal as withdrawn/not pressed, citing the CBDT circular that revised the monetary limit for filing appeals. The Revenue was granted liberty to approach for recall if exceptions applied.
The Tribunal noted that the tax effect in the appeals was below the monetary limit prescribed by the CBDT for filing appeals. The Departmental Representative conceded that the appeals were not maintainable.
The Tribunal noted that the tax effect in these appeals was below the monetary limit prescribed by the CBDT for filing appeals. The Departmental Representative conceded that the appeals were not maintainable. Therefore, the Tribunal dismissed the appeals.
The Tribunal noted that as per CBDT Circular No. 3/2018, appeals with a tax effect of Rs. 20.00 lakhs or less are generally not to be pursued, unless they fall under specific exceptions. Since the issues did not appear to fall under any exceptions, the appeals were dismissed.
The Tribunal noted that the appeal's tax effect was below the monetary limit specified in the CBDT circular. As no exceptions applied, the appeal was deemed withdrawn.
The Tribunal dismissed the revenue's appeals in limine as the tax effect was below the threshold specified in CBDT Circular No. 3/2018. The revenue was granted liberty to move a miscellaneous application if the issue fell under exceptions to the circular.
The Tribunal upheld the CIT(A)'s decision to restrict the disallowance to 12.5% of the alleged bogus purchases. This was based on previous decisions of the Tribunal and High Courts, and the assessee's agreement to the restricted addition.
The Tribunal noted that the tax effect was below the monetary limit specified in CBDT Circular No. 03/2018. Therefore, the revenue's appeal was dismissed based on this circular.
The Tribunal upheld the CIT(A)'s decision to restrict the disallowance to 12.5% of the alleged bogus purchases. The Tribunal noted that the assessee's counsel had agreed to this addition during the hearing.
The Tribunal noted that the tax effect was below the monetary limit specified in CBDT Circular No. 03/2018. Therefore, the appeals filed by the Revenue were dismissed.
The Tribunal held that the appeal was covered by CBDT Circular No. 03/2018, which sets monetary limits for filing appeals. Therefore, the revenue's appeal was dismissed.
The Tribunal noted that the tax effect in these appeals was below the threshold limit fixed by the CBDT for filing appeals. The Departmental Representative conceded that the appeals were not maintainable. Therefore, the Tribunal dismissed the appeals.
The Tribunal upheld the reopening of the assessment but modified the addition. It ruled that only the profit element on bogus purchases should be taxed, not the entire amount, especially when corresponding sales were not disputed.
The Tribunal noted that the appeal's tax effect was below the revised monetary limit specified by the CBDT. As no exceptions applied, the appeal was not pressed.
The Tribunal noted that the tax effect in the appeals was below the monetary limit prescribed by the CBDT for filing appeals. The Departmental Representative conceded that the appeals were not maintainable.
The Tribunal held that if no exempt income is received by the assessee, then no disallowance under Section 14A can be made. This decision was based on the jurisdictional High Court's ruling in a similar case.
The Tribunal dismissed the revenue's appeals in limine as the tax effect was below the threshold specified in CBDT Circular No. 3/2018. The revenue was given liberty to move for recall if exceptions applied.
The Tribunal allowed Pooja/function expenses based on consistent past rulings. It directed the AO to recompute Section 80HHC deduction considering High Court's ratio on Section 80IA(9) and allowed exclusion of Section 80HHC deduction for book profit computation.
The Tribunal dismissed the revenue's appeals in limine as the tax effect was below the threshold specified in CBDT Circular No. 3/2018. The revenue was precluded from pursuing appeals with a tax effect of Rs. 20.00 lakhs or less, unless an exception applied.
The tribunal dismissed the revenue's appeal, noting that the tax effect was below the monetary limit set by CBDT Circular No. 03/2018. The tribunal found no requirement for additional certificates as suggested by the revenue.
The Tribunal noted that as per CBDT Circular No. 3/2018, appeals with a tax effect of Rs. 20.00 lakhs or less are generally not to be pursued, unless they fall under specific exceptions. Since the issues did not appear to fall under any exceptions, the appeals were dismissed.
The Tribunal noted that the tax effect of the additions in dispute was below the monetary limit prescribed by CBDT Circular No. 03/2018. Therefore, the appeals were dismissed.
The tribunal noted that the tax effect was below the monetary limit for appeals as per CBDT Circular No. 03/2018. Therefore, the revenue's appeal was dismissed.
The Tribunal dismissed the appeals filed by the Revenue due to low tax effect, as per CBDT Circular No. 3/2018. Liberty was granted to the Revenue to file a miscellaneous application for recall if they intended to contest the appeal under specific conditions mentioned in the circular.
The Tribunal held that the appeal by the revenue was covered by the CBDT's low tax effect Circular No. 03/2018. The circular sets a monetary limit of Rs. 20 Lacs for appeals before the Appellate Tribunal.
The Tribunal held that the appeal was covered by CBDT Circular No. 03/2018, which sets a monetary limit for filing appeals. Therefore, the revenue's appeal was dismissed.
The Tribunal dismissed the appeals filed by the Revenue due to low tax effect, as per CBDT Circular No. 3/2018. Liberty was granted to the Revenue to file a miscellaneous application for recall if they intended to contest the appeal under specific conditions mentioned in the circular.
The Tribunal dismissed the appeals filed by the Revenue due to low tax effect, as per CBDT Circular No. 3/2018. Liberty was granted to the Revenue to file a miscellaneous application for recall if they intended to contest the appeal under specific conditions mentioned in the circular.
The Tribunal held that depreciation on moulds used in manufacturing electronic goods should be allowed at 30%, following its own consistent precedents. The disallowance under Section 14A was also confirmed as restricted by the CIT(A).
The Tribunal held that the appeals were covered by the CBDT circular which allows withdrawal of pending appeals below the specified tax limits. The Revenue could not establish any exceptions to this circular.
The Tribunal held that the appeals were covered by the CBDT circular which allows withdrawal of pending appeals below the specified tax limits. The Revenue could not establish any exceptions to this circular.
The Tribunal held that the appeal was covered by the CBDT circular regarding low tax effect. Therefore, the appeal filed by the Revenue was dismissed.
The Tribunal held that the assessee's efforts to let out the property were reasonable, supported by letters to the builder who had previously helped find a tenant for another property. The authorities below unreasonably doubted the assessee's claim.
The Tribunal held that the appeals were covered by the CBDT circular and, in the absence of any exceptions, dismissed them as withdrawn. The Revenue was granted liberty to seek recall if exceptions were found.
The Tribunal, applying the CBDT Circular dated 11.07.2018, deemed the appeals as withdrawn/not pressed. The Revenue was granted liberty to approach the Tribunal for re-institution if exceptions applied.
The Tribunal held that the appeals were covered by the CBDT circular which allows withdrawal of pending appeals below the specified tax limits. The Revenue could not establish any exceptions to this circular.
The Tribunal noted that the appeal's tax effect was below the monetary limit specified in the CBDT circular. As the Revenue did not demonstrate any exceptions, the appeal was dismissed as withdrawn.
The Tribunal upheld the CIT(A)'s decision, finding no reason to interfere with the deletion of additions for undisclosed sales receipts. Similarly, the addition for inflated purchases was also dismissed, affirming the CIT(A)'s findings.
The Tribunal dismissed the appeals filed by the Revenue due to low tax effect, as per CBDT Circular No. 3/2018. Liberty was granted to the Revenue to file a miscellaneous application for recall if they intended to contest the appeal under specific conditions mentioned in the circular.
The Tribunal noted that the tax effect in the appeals was below the monetary limit prescribed by the CBDT for filing appeals. The Departmental Representative conceded that the appeals were not maintainable.
The Tribunal held that the appeal was covered by CBDT Circular No. 03/2018, which sets a monetary limit for filing appeals. Therefore, the revenue's appeal was dismissed.
The Tribunal noted that the appeal's tax effect was below the monetary limit specified in the CBDT circular. Since no exceptions applied, the appeal was deemed withdrawn.
The Tribunal held that compensation paid to tenants for vacating premises is an expenditure incurred wholly and exclusively in connection with the transfer of a capital asset and is deductible. Regarding book profits, the Tribunal followed the Supreme Court ruling that AO cannot go beyond the P&L account except as provided in the Explanations.
The Tribunal noted that the tax effect was below the monetary limit specified in CBDT Circular No. 03/2018 for filing appeals. Therefore, the appeal was dismissed.
The Tribunal noted that the tax effect in these appeals was below the monetary limit prescribed by the CBDT for filing appeals. The Departmental Representative conceded that the appeals were not maintainable and did not fall under any exceptions.
The Tribunal held that income from sale and purchase of securities by an FII is to be taxed as capital gains. It further affirmed that such income is not taxable in India under Article 13(6) of the India-Switzerland Tax Treaty, and the banking branch does not constitute a Permanent Establishment for this income.
The tribunal held that segmental results should be considered for determining the arm's length price, given the distinct nature of the two segments. Issues regarding common expense allocation and additions based on Form 26AS and brought forward losses were restored to the Assessing Officer for fresh examination.
The Tribunal held that the assessee is entitled to arrange its affairs and follow a recognized method of accounting. Since the assessee consistently followed the project completion method, which is a recognized method, it was not required to be substituted by the percentage completion method.
The Tribunal noted that the appeal's tax effect was below the revised monetary limit for filing appeals by the Department. As no exceptions applied, the appeal was deemed withdrawn.
The Tribunal upheld the CIT(A)'s decision to delete the additions. It found that the CIT(A) had correctly considered the joint ownership of the flat and the source of funds for its purchase, based on documentary evidence.