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157 orders · Page 1 of 4
The Tribunal held that if the written-back amount was indeed offered for taxation in a later year, no addition should be made for the current year. For the remaining amount, the Tribunal found that services were rendered and remitted the matter for fresh determination of ALP using an appropriate method.
The Tribunal dismissed the Revenue's appeal, holding that the TPO's concession in remand proceedings on both the cash PLI and custom duty adjustment issues barred the Revenue from challenging them. The assessee's cross-objection was dismissed as not pressed.
The Tribunal held that if the written-back amount was indeed offered for taxation in a later year, no addition should be made for the current year. For the remaining amount, the Tribunal found that services were rendered and remitted the matter for fresh determination of ALP using an appropriate method.
For AY 2011-12, the Tribunal quashed the penalty as the AO initiated proceedings for inaccurate particulars but levied penalty for concealment of income, contrary to the jurisdictional High Court's decision. For AY 2012-13, the Tribunal upheld the CIT(A)'s decision to restrict the addition to 10% on bogus Hawala purchases, following a previous Tribunal ruling.
The Tribunal found the assessee's arguments acceptable and directed the Assessing Officer to re-adjudicate the matter after giving effect to the previous Tribunal order. The Assessing Officer was instructed to quantify the HUF's income and consider it as a source for the assessee's deposits.
The Tribunal dismissed the Revenue's appeal due to low tax effect. For the assessee's appeal, the Tribunal restricted the disallowance of transportation charges to 5% on an ad-hoc basis, considering past precedents.
The Tribunal held that the assessee deserved adjustments for salary and travel costs in the initial year of operation for ALM services. For software development services, the matter was restored to the AO/TPO for fresh adjudication regarding the appropriate method and comparables. The Revenue's appeal regarding inclusion of comparables was dismissed.
The Tribunal held that the assessee deserved adjustments for salary and travel costs in the initial year of operation for ALM services. For software development services, the matter was restored to the AO/TPO for fresh adjudication regarding the appropriate method and comparables. The Revenue's appeal regarding inclusion of comparables was dismissed.
The Tribunal dismissed the Revenue's appeal due to low tax effect. For the assessee's appeal, the Tribunal restricted the disallowance of transportation charges to 5% on an ad-hoc basis, considering past precedents.
The Tribunal found the assessee's arguments acceptable and directed the Assessing Officer to re-adjudicate the matter after giving effect to the previous Tribunal order. The Assessing Officer was instructed to quantify the HUF's income and consider it as a source for the assessee's deposits.
The Tribunal found the assessee's arguments acceptable and directed the Assessing Officer to re-adjudicate the matter after giving effect to the previous Tribunal order. The Assessing Officer was instructed to quantify the HUF's income and consider it as a source for the assessee's deposits.
The Tribunal directed the Assessing Officer to grant a telescopic benefit of Rs. 1 lakh on cash withdrawals. The issue regarding the source of income from the Bigger HUF was remanded for fresh adjudication after the Assessing Officer gives effect to a previous Tribunal order.
The Tribunal held that the grounds related to transfer pricing were academic. For Section 14A, the issue was remitted to the AO for adjudication in line with previous orders. The claim for deduction under Section 35(2AB) was allowed following earlier precedents. The disallowance of additional depreciation was allowed, following High Court judgments.
The Tribunal noted that the tax effect was below the monetary limit prescribed by a CBDT circular for filing appeals. Consequently, the appeal was dismissed as withdrawn based on the Assessing Officer's request.
The Tribunal dismissed the Revenue's appeal due to low tax effect as per CBDT circular. The assessee's cross-objection regarding bad debts was allowed for statistical purposes, with a direction to the Assessing Officer to verify the amount paid as advance.
The Tribunal held that the Pr. CIT erred in assuming jurisdiction under section 263 as the Assessing Officer had applied his mind and taken a view on the issue of URD purchases. The Pr. CIT's decision to take another possible view was not permitted in law.
The Tribunal held that the appeals filed by the Revenue were not maintainable due to the low tax effect. Consequently, the appeals were dismissed as withdrawn in terms of the CBDT Circular.
The Tribunal held that the Pr. CIT erred in assuming jurisdiction under section 263 as the Assessing Officer had applied his mind and taken a view on the issue of URD purchases. The Pr. CIT's decision to take another possible view was not permitted in law.
The Tribunal dismissed the Revenue's appeal without going into the merits of the case. This was solely based on the tax effect being below the monetary limit prescribed by the CBDT circulars for filing appeals.
The Tribunal held that the Pr. CIT erred in assuming jurisdiction under section 263 as the Assessing Officer had applied his mind and taken a view on the issue of URD purchases. The Pr. CIT's decision to take another possible view was not permitted in law.
The Tribunal held that ad-hoc disallowance of 10% of bogus purchases is not warranted. The addition should be restricted to the difference between the gross profit rate on genuine and bogus purchases.
The Tribunal held that the appeals filed by the Revenue were not maintainable due to the low tax effect. Consequently, the appeals were dismissed as withdrawn in accordance with the CBDT Circular.
The Tribunal held that the commission payment issue needed re-examination by the Assessing Officer. For aircraft expenses, the disallowance was restricted to 15%. The disallowance under Section 14A was restored to the Assessing Officer for recomputation.
The Tribunal held that the Pr. CIT erred in assuming jurisdiction under section 263 as the Assessing Officer had applied his mind and taken a view on the issue of URD purchases. The Pr. CIT's decision to take another possible view was not permitted in law.
The Tribunal held that disallowance under Section 14A cannot be added to book profit for Section 115JB purposes, following the Bombay High Court. It also allowed grounds related to transfer pricing adjustments and employee contributions to PF/ESIC, while dismissing grounds not pressed by the assessee.
The Tribunal held that the Pr. CIT erred in assuming jurisdiction under section 263 as the Assessing Officer had applied his mind and taken a view on the issue of URD purchases. The Pr. CIT's decision to take another possible view was not permitted in law.
The Tribunal upheld the CIT(A)'s decision, agreeing that the date of commencement for the buildings in question should be considered from the building plan sanction date, not the layout commencement date. Therefore, the deduction under Section 80IB(10) was rightly allowed.
The Tribunal upheld the CIT(A)'s decision, agreeing that the date of commencement for the buildings in question should be considered from the building plan sanction date, not the layout commencement date. Therefore, the deduction under Section 80IB(10) was rightly allowed.
The Tribunal held that the grounds raised by the Revenue were not maintainable due to the low tax effect. Consequently, the appeals were dismissed as withdrawn in terms of the CBDT Circular.
The Tribunal held that the Pr. CIT erred in assuming jurisdiction under section 263 as the Assessing Officer had applied his mind and taken a view on the issue of URD purchases. The Pr. CIT's decision to take another possible view was not permitted in law.
The Tribunal held that foreign exchange fluctuation on operating transactions should be considered as operating in nature, following previous judicial pronouncements. Consequently, the grounds of appeal related to this issue were dismissed.
The Tribunal held that the commission payment issue needed re-examination by the Assessing Officer. For aircraft expenses, the disallowance was restricted to 15%. The disallowance under Section 14A was restored to the Assessing Officer for recomputation.
The Tribunal held that the notice under Section 148 was issued before the approval from the Principal Commissioner of Income Tax was obtained, rendering the reassessment proceedings void ab initio. Therefore, the reassessment was quashed.
The Tribunal held that disallowance under Section 14A cannot be added to book profit for Section 115JB purposes, following the Bombay High Court. It also allowed grounds related to transfer pricing adjustments and employee contributions to PF/ESIC, while dismissing grounds not pressed by the assessee.
The Tribunal held that the commission payment issue needed re-examination by the Assessing Officer. For aircraft expenses, the disallowance was restricted to 15%. The disallowance under Section 14A was restored to the Assessing Officer for recomputation.
The Tribunal held that the Pr. CIT erred in assuming jurisdiction under section 263 as the Assessing Officer had applied his mind and taken a view on the issue of URD purchases. The Pr. CIT's decision to take another possible view was not permitted in law.
The Tribunal followed a precedent where similar issues were remanded to the AO for fresh consideration. Specifically, the issue of concessional sale of sugar below cost price was remanded to ascertain the cost price and determine appropriation of profit.
The Tribunal followed a precedent where similar issues were remanded to the AO for fresh consideration. Specifically, the issue of concessional sale of sugar below cost price was remanded to ascertain the cost price and determine appropriation of profit.
The Tribunal followed a precedent where similar issues were remanded to the AO for fresh consideration. Specifically, the issue of concessional sale of sugar below cost price was remanded to ascertain the cost price and determine appropriation of profit.
The Tribunal followed a precedent where similar issues were remanded to the AO for fresh consideration. Specifically, the issue of concessional sale of sugar below cost price was remanded to ascertain the cost price and determine appropriation of profit.
The Tribunal followed a precedent where similar issues were remanded to the AO for fresh consideration. Specifically, the issue of concessional sale of sugar below cost price was remanded to ascertain the cost price and determine appropriation of profit.
The Tribunal followed a precedent where similar issues were remanded to the AO for fresh consideration. Specifically, the issue of concessional sale of sugar below cost price was remanded to ascertain the cost price and determine appropriation of profit.
The Tribunal followed a precedent where similar issues were remanded to the AO for fresh consideration. Specifically, the issue of concessional sale of sugar below cost price was remanded to ascertain the cost price and determine appropriation of profit.
The Tribunal followed a precedent where similar issues were remanded to the AO for fresh consideration. Specifically, the issue of concessional sale of sugar below cost price was remanded to ascertain the cost price and determine appropriation of profit.
The Tribunal followed a precedent where similar issues were remanded to the AO for fresh consideration. Specifically, the issue of concessional sale of sugar below cost price was remanded to ascertain the cost price and determine appropriation of profit.
The Tribunal found that the assessee was not given a proper opportunity before the Assessing Officer and CIT(A). Considering refilling as manufacturing, the matter was remanded to the Assessing Officer for fresh verification.
The Tribunal followed a precedent where similar issues were remanded to the AO for fresh consideration. Specifically, the issue of concessional sale of sugar below cost price was remanded to ascertain the cost price and determine appropriation of profit.
The Tribunal upheld the CIT(A)'s decision to delete the additions. It found that the unconsidered consideration was not yet received, the commission payments were supported by confirmations and PANs, and the development expenses were justified by the agreement and the work done.
The Tribunal followed a precedent where similar issues were remanded to the AO for fresh consideration. Specifically, the issue of concessional sale of sugar below cost price was remanded to ascertain the cost price and determine appropriation of profit.
The Tribunal followed a precedent where similar issues were remanded to the AO for fresh consideration. Specifically, the issue of concessional sale of sugar below cost price was remanded to ascertain the cost price and determine appropriation of profit.