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433 orders · Page 9 of 9
The Tribunal dismissed the Revenue's appeal as not maintainable. This was based on a CBDT circular directing withdrawal of appeals where the tax effect is below a certain threshold.
The Tribunal held that disallowance of interest under the second limb of Rule 8D(2) was not warranted due to sufficient own funds. However, the disallowance of administrative expenses under the third limb of Rule 8D(2) was remanded to the AO for verification of the assessee's workings.
The Tribunal held that unexplained cash deposits in bank accounts are liable to be added as income from undisclosed sources, especially when the assessee had previously accepted such deposits as undisclosed income.
The Tribunal held that lease rental income from an IT park, which is operated and maintained as an infrastructure facility, should be treated as business income. This was supported by CBDT circulars and the principle of consistency in past assessments.
The Tribunal partly allowed the assessee's appeal. It directed the AO to consider investments yielding exempt income for disallowance under Rule 8D(2)(iii) based on a Special Bench decision. The revision order on the exchange rate issue was quashed due to lack of opportunity for the assessee.
The Tribunal held that computer peripherals like printers are part of the computer system and are entitled to depreciation at the rate of 60%. The orders of the lower authorities were set aside.
The Tribunal held that the cash refunds were sufficiently evidenced by the assessee's balance sheet, ledger accounts, and confirmations from the refunding parties, and the Revenue's case was based on suspicion. The Tribunal also found that the Ramzan expenses were not sufficiently linked to business purposes and upheld the addition.
The Tribunal held that 100% disallowance for bogus purchases is not permissible when sales are not doubted, as sales are impossible without actual purchases. The addition should be limited to the profit element embedded in such purchases.
The Tribunal held that the issue needed to be examined by the Assessing Officer to prevent double taxation if the reversal of provisions had increased the assessee's income in the current year. The matter was remitted to the Assessing Officer for fresh consideration.
The Tribunal condoned the delay, finding a reasonable cause. It set aside the ex-parte order of the CIT(A) and remanded the matter back for a decision on merits after providing the assessee with a reasonable opportunity of hearing.
The Tribunal held that the appeals filed by the Revenue were not maintainable as the tax effect was below the prescribed monetary limit. The cross-objections filed by the assessees were rendered infructuous.
The Tribunal dismissed the Revenue's appeal as not maintainable, citing CBDT circulars that set monetary limits for appeals. The Tribunal noted that the tax effect was below these limits and followed a coordinate bench's decision on the circular's applicability.
The Tribunal held that no penalty is leviable on an estimated disallowance. Therefore, the penalty levied by the Assessing Officer was deleted.
The Tribunal held that the assessment framed under Section 153C was bad in law because the AO had not recorded the necessary satisfaction as required by law. The seized documents were also found to be recorded in the regular books of account.
The Tribunal held that the assessment framed under Section 153C was bad in law because the AO had not recorded the necessary satisfaction as required by law. The seized documents were also found to be recorded in the regular books of account.
The Tribunal held that the assessment framed under Section 153C was bad in law because the AO had not recorded the necessary satisfaction as required by law. The seized documents were also found to be recorded in the regular books of account.
The Tribunal held that the assessment framed under Section 153C was bad in law because the AO had not recorded the necessary satisfaction as required by law. The seized documents were also found to be recorded in the regular books of account.
The Tribunal held that when sales are not doubted, a 100% disallowance for bogus purchases is not justified, as sales are impossible without actual purchases. The addition should be limited to the extent of bringing the gross profit rate on such purchases to the same level as other genuine purchases.
The Tribunal held that VGSIPL is an independent and separate entity engaged in selling cars on a principal-to-principal basis and does not constitute a PE of Audi AG in India. Consequently, income earned by Audi AG from sales to VGSIPL is not taxable in India.
The Tribunal held that a 100% disallowance for bogus purchases is not permissible when sales are not doubted, as sales are impossible without purchases. The addition should be limited to the profit element embedded in such purchases, aligning the gross profit rate with that of genuine purchases.
The Tribunal held that 100% disallowance for bogus purchases is not permissible when sales are not doubted, as sales are impossible without actual purchases. The addition should be limited to the profit element embedded in such purchases.
The Tribunal dismissed the appeal filed by the Revenue. This was based on the Departmental Representative's submission that the tax effect of the relief granted by the CIT(A) was below Rs. 50 lacs, making the appeal not maintainable as per CBDT Circular No. 17 of 2019.
The Tribunal held that the assessee's conduct was bonafide as the bad debt was written off in the books of account. Therefore, the penalty under Section 271(1)(c) was not leviable.
The Tribunal held that 100% disallowance for bogus purchases is not permissible when sales are not doubted. The addition should be limited to the extent of bringing the gross profit rate on bogus purchases to the same level as genuine purchases.
The Tribunal held that the revision exercise carried out by the CIT was bad in law. The Assessing Officer had already examined the issues during the assessment proceedings, and the revision order was quashed.
The Tribunal held that a 100% disallowance for bogus purchases is not justified when sales are not doubted. The addition should be limited to the extent of bringing the gross profit rate on such purchases to the same level as other genuine purchases.
The Tribunal directed the AO to restrict the disallowance to the assessee's suo motu disallowance of ₹27,57,805. Additionally, it held that no disallowance relatable to exempt income can be made while computing book profit under Section 115JB.
The Tribunal held that Section 115JB, as it stood prior to amendment by the Finance Act, 2012, was not applicable to banking companies. It also ruled that disallowance under Section 14A was not permissible for banking businesses and that provisions for expenses where the payee was not identifiable were not subject to TDS disallowance under Section 40(a)(ia).
The Tribunal held that 100% disallowance for bogus purchases is not permissible when sales are not doubted, as sales are impossible without purchases. The addition should be limited to the profit element embedded in such purchases.
The Tribunal held that 100% disallowance for bogus purchases is not justified when sales are not doubted. The addition should be limited to the extent of bringing the gross profit rate on such purchases to the same level as genuine purchases.
The Tribunal held that 100% disallowance for bogus purchases is not justified when sales are not doubted. The addition should be limited to the extent of bringing the gross profit rate on such purchases to the same level as genuine purchases.
The Tribunal held that 100% disallowance for bogus purchases is not justified when sales are not doubted. The addition should be limited to the extent of bringing the gross profit rate on such purchases to the same level as genuine purchases.