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The Tribunal held that the orders passed by the AO were barred by limitation. Since the appeals were allowed on the legal ground of limitation, the issues on merits were not considered.
The Tribunal held that the orders passed by the AO were barred by limitation. Since the appeals were allowed on the legal ground of limitation, the issues on merits were not considered.
The Tribunal held that the orders passed by the AO were barred by limitation. Since the appeals were allowed on the legal ground of limitation, the issues on merits were not considered.
The Tribunal held that the orders passed by the AO were barred by limitation. Since the appeals were allowed on the legal ground of limitation, the issues on merits were not considered.
The Tribunal held that the AO's order was passed beyond the period of two years from the end of the financial year in which the last TDS statement was filed. The Tribunal further clarified that a subsequent amendment enlarging the limitation period cannot revive an already time-barred action.
The Tribunal held that the orders passed by the AO were barred by limitation. Since the appeals were allowed on the legal ground of limitation, the issues on merits were not considered.
The Tribunal upheld the order of the CIT(A), finding that the issue was squarely covered by its own previous order for the assessment year 2010-11 on identical facts. The Tribunal relied on the decision of the Karnataka High Court in CIT Vs. Expert Outsource (P) Ltd.
The Tribunal noted that while the assessee claimed to have submitted all details, no evidence was provided to the Tribunal to support this. Therefore, the Tribunal granted one more opportunity to the assessee to furnish all details to the CIT(Exemption).
The Tribunal found that the CIT(Appeals) did not provide specific findings on the assessee's submissions regarding an excess provision for consumables. The Tribunal noted that the issue required factual verification and detailed examination.
The Tribunal dismissed the appeal filed by the Revenue as withdrawn, granting liberty to restore it if the assessee fails to settle disputes under the Vivad Se Vishwas Scheme.
The Tribunal condoned the 4-day delay in filing the appeals. It held that since the appeals were dismissed for non-prosecution, the rights and liabilities were not adjudicated on merits, and a final opportunity should be given to the assessee.
The assessee requested to withdraw the appeal in light of opting for the Vivad Se Vishwas scheme. The Revenue had no objection to the withdrawal.
The Tribunal condoned the 4-day delay in filing the appeals. It held that since the appeals were dismissed for non-prosecution, the rights and liabilities were not adjudicated on merits, and a final opportunity should be given to the assessee.
The Tribunal rejected the assessee's claims for adjustments due to foreign exchange fluctuation and excess custom duty. However, it directed the AO/TPO to recompute the working capital adjustment and restrict the transfer pricing addition to international transactions only.
The Tribunal condoned the 4-day delay in filing the appeals. It held that since the appeals were dismissed for non-prosecution, the rights and liabilities were not adjudicated on merits, and a final opportunity should be given to the assessee.
The assessee requested to withdraw the appeal due to the application filed under the Vivad Se Vishwas Scheme. The Revenue had no objection to the withdrawal.
The Tribunal accepted the assessee's contention that the appeal was filed in duplicate. Consequently, the appeal was dismissed on this ground.
The Tribunal found that the CIT(A) had dismissed the appeal ex-parte. Considering the lack of a proper hearing opportunity for the assessee, the Tribunal set aside the impugned order.
The tribunal allowed the assessee to withdraw the appeal. Consequently, the appeal filed by the assessee was dismissed as withdrawn.
The Tribunal held that while the assessee failed to provide sufficient evidence, Income Tax legislation is welfare-oriented. Therefore, one more opportunity should be granted to the assessee to present necessary documents.
The Tribunal noted that the Revenue had no objection to the withdrawal applications. Therefore, the Tribunal permitted the withdrawal of the appeals.
The Tribunal set aside the CIT(Exemption)'s order and remanded the matter back for fresh adjudication. The assessee was granted one more opportunity to furnish the necessary details and evidence.
The Tribunal permitted the withdrawal of the appeals. The Revenue had no objection to the withdrawal applications filed by the assessees.
The Tribunal noted that the Revenue had no objection to the withdrawal applications. Therefore, the Tribunal permitted the withdrawal of the appeals.
The Tribunal permitted the withdrawal of the appeals as the assessees had opted for the Vivad Se Vishwas scheme. The Revenue did not object to the withdrawal.
The Tribunal held that the appellant was prevented by sufficient cause from complying with the notices due to the Covid-19 pandemic. Therefore, the matter was remitted to the CIT(E) for fresh consideration.
The Tribunal noted that the Revenue had no objection to the withdrawal of appeals. Therefore, the Tribunal permitted the withdrawal of all the appeals filed by the assessees.
The Tribunal allowed the assessee to withdraw the appeal. Consequently, the appeal filed by the assessee was dismissed as withdrawn.
The Tribunal noted that the Revenue had no objection to the withdrawal applications. Consequently, the Tribunal permitted the withdrawal of the appeals.
The Tribunal held that interest on sticky advances, where recovery is uncertain, cannot be taxed on accrual basis, even if the assessee follows the mercantile system. This is based on the principle of taxing only real income and is akin to the treatment of interest on Non-Performing Assets (NPAs).
The Tribunal held that the assessee failed to prove the genuineness of the donations and the identity of the donors. The identical donation amounts from a large number of persons and unserved notices indicated that the transactions were not genuine.
The Tribunal held that the Revenue failed to establish that incriminating documents directly related to the assessee trust were found during the search. Furthermore, the assessee's application under Rule 27 of ITAT Rules to raise new grounds was dismissed.
The Tribunal held that the genuineness of the trust's objects and activities are the only criteria for granting registration under Section 12AA. The issue of tax payment on corpus fund is to be examined during assessment proceedings, not at the registration stage.
The Tribunal held that the CIT(A) should not dismiss an appeal for non-prosecution without considering the merits of the case. The matter was remitted back to the CIT(A) for a fresh decision.
The Tribunal held that advances to suppliers and advances from customers should be included in working capital adjustments for transfer pricing. It also ruled that Fives Cail KCP Ltd. was not a comparable company due to its significant service income and lack of segmental information for manufacturing.
The Tribunal noted that the quantum appeal regarding the additions had been set aside to the Assessing Officer. Therefore, the penalty order was also set aside and the matter was remanded to the Assessing Officer.
The tribunal granted permission to the appellant to withdraw the appeal. Consequently, the appeal filed by the assessee was dismissed as withdrawn.
The Tribunal held that the Revenue failed to establish that incriminating documents directly related to the assessee trust were found during the search. Furthermore, the assessee's application under Rule 27 of ITAT Rules to raise new grounds was dismissed.
The Tribunal held that the Revenue failed to establish that incriminating documents directly related to the assessee trust were found during the search. Furthermore, the assessee's application under Rule 27 of ITAT Rules to raise new grounds was dismissed.
The Tribunal held that the Revenue failed to establish that incriminating documents directly related to the assessee trust were found during the search. Furthermore, the assessee's application under Rule 27 of ITAT Rules to raise new grounds was dismissed.
The Tribunal held that the Revenue failed to establish that incriminating documents directly related to the assessee trust were found during the search. Furthermore, the assessee's application under Rule 27 of ITAT Rules to raise new grounds was dismissed.
The Tribunal held that the Revenue failed to establish that incriminating documents directly related to the assessee trust were found during the search. Furthermore, the assessee's application under Rule 27 of ITAT Rules to raise new grounds was dismissed.
The Tribunal held that the Revenue failed to establish that incriminating documents directly related to the assessee trust were found during the search. Furthermore, the assessee's application under Rule 27 of ITAT Rules to raise new grounds was dismissed.
The Tribunal held that the CIT(A) does not have the power to set aside an issue to the Assessing Officer, but the Tribunal does. Therefore, the Tribunal remitted the ground of appeal back to the Assessing Officer for examination based on the Supreme Court's decision in CIT Vs. Krishna Sahakari Sakhar Karkhana Ltd.
The assessee requested to withdraw the appeals due to opting for the Vivad Se Vishwas scheme. The Revenue had no objection, and the tribunal permitted the withdrawal.
The assessee requested to withdraw the appeals due to opting for the Vivad Se Vishwas scheme. The revenue had no objection, and the tribunal permitted the withdrawal.
The Tribunal found that the tax effect involved in the appeal was below the enhanced monetary limit prescribed by the CBDT circulars. Therefore, the appeal was dismissed without going into the merits of the issues raised.
The Tribunal held that the Assessing Officer cannot substitute the actual consideration received by the assessee with the fair market value or ready reckoner rates, as there is no specific provision in the Income Tax Act that allows for such substitution in this context. The 'full value of consideration' refers to the actual amount received or accrued.
The Tribunal held that the Assessing Officer cannot substitute the actual consideration received by the assessee with the fair market value or ready reckoner rates, as there is no specific provision in the Income Tax Act that allows for such substitution in this context. The 'full value of consideration' refers to the actual amount received or accrued.
The Tribunal held that the Assessing Officer cannot substitute the actual consideration received with the fair market value unless specific provisions like Section 50C are applicable. The 'full value of consideration' refers to the actual amount received or accrued, not necessarily the market value.