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230 orders · Page 3 of 5
The Tribunal held that in the interest of justice, one more opportunity should be given to the assessee. The case was set aside to the CIT(A) for fresh adjudication after providing an opportunity to the assessee to present facts and documents.
The ITAT condoned the 17-day delay in the assessee's appeal before the CIT(A), citing the principle of substantial justice over technicalities. The CIT(A) was directed to decide the appeal on merits.
The Tribunal held that the Resale Price Method (RPM) is the most appropriate method for benchmarking transactions where goods are purchased from an associated enterprise and resold as such without value addition. The Tribunal also excluded several comparables used by the TPO and DRP.
The Tribunal upheld the additions made by the AO, stating that the assessee failed to provide any documentary evidence to substantiate its claim of trading activity and the source of cash deposits. The reopening of assessment was also found to be valid.
The Tribunal upheld the disallowance of transportation charges and salary expenses, stating that the assessee failed to provide sufficient documentary evidence to prove the genuineness of these expenditures. The AO's disallowance was considered justified.
The tribunal observed that the reasons provided for the delay were insufficient and the doctor's certificate did not explain the delay. Given the inordinate delay and the assessee's failure to appear, the tribunal did not condone the delay.
The Tribunal set aside the order of the CIT(A) and remanded the matter back for a fresh decision. The assessee was directed to produce all documents on the first hearing.
The Tribunal held that the Assessing Officer had made sufficient inquiries and was satisfied with the assessee's explanation and supporting documents before allowing the Section 54F exemption. Therefore, the Commissioner's revisionary order was not sustainable as the original assessment order was not erroneous or prejudicial to the revenue.
The tribunal dismissed the ground of violation of natural justice. It allowed the appeal regarding Section 14A disallowance due to no exempt income earned. The addition under Section 2(22)(e) was upheld, and the rental income was directed to be treated as 'Income from House Property', with a direction for AO to verify the difference in rent. The addition to book profit was deleted.
The Tribunal dismissed the Revenue's appeal due to low tax effect, as it fell below the revised monetary limit set by the CBDT. Consequently, the assessee's cross-objection was also dismissed as infructuous.
The Tribunal dismissed the assessee's appeal as withdrawn. However, the assessee was permitted to seek recall of the order if Form-5 was not issued for technical reasons.
The tribunal noted the withdrawal application filed by the assessee, supported by the settlement under the Vivad se Vishwas Act. Consequently, the appeal was dismissed as withdrawn.
The Tribunal held that the assessee had furnished all details regarding the claim, and the AO's rejection of the claim did not automatically imply furnishing inaccurate particulars. The penalty was deleted based on the principle that a non-maintainable claim alone does not constitute furnishing inaccurate particulars.
The Tribunal held that the assessee had sufficiently proved receipt of advisory services from its group entity. The lower authorities erred in rejecting the services in entirety, and thus the impugned adjustment was deleted.
The Tribunal directed the Transfer Pricing Officer to recompute the arm's length price at the transaction level, considering audited book results and excluding non-operating items. Income from management support services was also to be excluded from AE sales for TP adjustment.
The Tribunal found that the assessee failed to provide a reasonable cause for the inordinate delay in filing the appeal. The reasons provided were not considered acceptable, especially for a bank with professional expertise.
The Tribunal held that the assessee maintained a proper melting gain/loss register without any defects pointed out by the AO. Following a previous ITAT decision in the assessee's own case for an earlier year, the Tribunal upheld the CIT(A)'s deletion of the addition.
The Tribunal held that the assessee was entitled to exemption under Section 11. It relied on a previous decision for AY 2011-12 in the assessee's own case, which found that the trust's activities were confined to medical relief, education, and relief to the poor, and did not fall under the 'advancement of any other object of general public utility' which would attract the proviso to Section 2(15).
The Tribunal held that the penalty was not maintainable as the assessee had a specific basis for estimating the cost of acquisition, and the AO had not proven concealment of income or filing of inaccurate particulars. The penalty was directed to be deleted.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.
The tribunal held that late fees under Section 234E could not be levied for periods prior to June 1, 2015, as the mechanism for computation and demand was introduced only from that date. Therefore, the levy of late fees for the specified financial years was not legally sustainable.
The tribunal held that late fees under Section 234E could not be levied for periods prior to June 1, 2015, as the mechanism for computation and demand was introduced only from that date. Therefore, the levy of late fees for the specified financial years was not legally sustainable.
The tribunal held that late fees under Section 234E could not be levied for periods prior to June 1, 2015, as the mechanism for computation and demand was introduced only from that date. Therefore, the levy of late fees for the specified financial years was not legally sustainable.
The tribunal held that late fees under Section 234E could not be levied for periods prior to June 1, 2015, as the mechanism for computation and demand was introduced only from that date. Therefore, the levy of late fees for the specified financial years was not legally sustainable.
The tribunal held that late fees under Section 234E could not be levied for periods prior to June 1, 2015, as the mechanism for computation and demand was introduced only from that date. Therefore, the levy of late fees for the specified financial years was not legally sustainable.
The tribunal held that late fees under Section 234E could not be levied for periods prior to June 1, 2015, as the mechanism for computation and demand was introduced only from that date. Therefore, the levy of late fees for the specified financial years was not legally sustainable.
The Tribunal held that the penalty notice was bad in law as it failed to specify the exact default, making the penalty proceedings void. Following the jurisdictional High Court's decision, the penalty was directed to be deleted.
The Tribunal held that the penalty notice was bad in law as it failed to specify the exact default, making the penalty proceedings void. Following the jurisdictional High Court's decision, the penalty was directed to be deleted.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.
The Tribunal held that the penalty notice was bad in law as it failed to specify the exact default, making the penalty proceedings void. Following the jurisdictional High Court's decision, the penalty was directed to be deleted.
The tribunal held that late fees under Section 234E could not be levied for periods prior to June 1, 2015, as the mechanism for computation and demand was introduced only from that date. Therefore, the levy of late fees for the specified financial years was not legally sustainable.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.
The Tribunal found that while the CIT(A) had given opportunities, the assessee failed to represent its case. However, in the interest of justice, the case was remanded back to the CIT(A) for one more effective opportunity.
The Tribunal dismissed the Revenue's appeal due to low tax effect (LTE) as per CBDT circulars. The assessee's cross-objection was rendered infructuous.
The tribunal held that late fees under Section 234E could not be levied for periods prior to June 1, 2015, as the mechanism for computation and demand was introduced only from that date. Therefore, the levy of late fees for the specified financial years was not legally sustainable.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.
The Tribunal held that Section 234E of the Income-tax Act, along with the mechanism for levying late fees, was made effective only from June 1, 2015. Therefore, fees cannot be levied for periods prior to this date.