Loading ITAT cases…
67 orders · Page 2 of 2
The Tribunal held that the Arm's Length Price (ALP) for corporate guarantee commission should be benchmarked at 0.50%. For notional interest on outstanding guarantee commission, the TPO was directed to adopt USD LIBOR rates. The addition of notional interest on share application money was deleted, following the principle that share transactions should not be re-characterized as loans without sufficient material.
The Tribunal upheld the Assessing Officer's addition of Rs. 2.16 Crores as income from other sources, considering it as cash deposits violating FEMA regulations. However, it dismissed grounds related to interest expenditure, finding the CIT(A)'s order to be correct.
The Tribunal upheld the Assessing Officer's addition of Rs. 2.16 Crores as income from other sources, considering it as cash deposits violating FEMA regulations. However, it dismissed grounds related to interest expenditure, finding the CIT(A)'s order to be correct.
The Tribunal upheld the Assessing Officer's addition of Rs. 2.16 Crores as income from other sources, considering it as cash deposits violating FEMA regulations. However, it dismissed grounds related to interest expenditure, finding the CIT(A)'s order to be correct.
The Tribunal held that the revenue failed to establish that the assessee AOP received sale consideration over and above the sale consideration mentioned in the books of accounts. The Tribunal also noted that the purchasers were not examined to confirm the payment of 'on money'.
The Tribunal held that the CPC has the power to make adjustments under Section 143(1) for incorrect claims apparent from the return, including belated payments of employee contributions. The disallowance was upheld based on Supreme Court and High Court decisions.
The Tribunal held that the disallowance made by the CPC under Section 143(1) for belated payments of employees' contribution to PF and ESI is valid. This is because the scope of Section 143(1) has been enlarged to include adjustments for incorrect claims apparent from the return, and the Supreme Court has settled the issue regarding the allowability of such belated payments.
The Tribunal held that the assessee had explained the source of the deposits as money received from his father, considering the father's agricultural holdings. Therefore, the addition made under Section 115BBE was directed to be deleted.
The Tribunal held that the disallowance of delayed PF/ESI contributions was justified based on the Supreme Court's decision in Checkmate Services Pvt. Ltd. It further held that the Section 80P deduction was rightly disallowed because the returns were filed after the due date, as per the amendment to Section 80AC.
The Tribunal held that the disallowance made by the CPC under Section 143(1) for belated payments of employees' contribution to PF and ESI is valid. This is because the scope of Section 143(1) has been enlarged to include adjustments for incorrect claims apparent from the return, and the Supreme Court has settled the issue regarding the allowability of such belated payments.
The Tribunal held that the disallowance made by the CPC under Section 143(1) for belated payments of employees' contribution to PF and ESI is valid. This is because the scope of Section 143(1) has been enlarged to include adjustments for incorrect claims apparent from the return, and the Supreme Court has settled the issue regarding the allowability of such belated payments.
The Tribunal held that the disallowance of delayed PF/ESI contributions was justified based on the Supreme Court's decision in Checkmate Services Pvt. Ltd. It further held that the Section 80P deduction was rightly disallowed because the returns were filed after the due date, as per the amendment to Section 80AC.
The Tribunal held that the disallowance of delayed PF/ESI contributions was justified based on the Supreme Court's decision in Checkmate Services Pvt. Ltd. It further held that the Section 80P deduction was rightly disallowed because the returns were filed after the due date, as per the amendment to Section 80AC.
The tribunal permitted the assessee to withdraw the appeal as the revenue did not object. Therefore, the appeal filed by the assessee was dismissed as withdrawn.
The Tribunal held that the disallowance made by the CPC under Section 143(1) for belated payments of employees' contribution to PF and ESI is valid. This is because the scope of Section 143(1) has been enlarged to include adjustments for incorrect claims apparent from the return, and the Supreme Court has settled the issue regarding the allowability of such belated payments.
The Tribunal found that there was a suppression of turnover by the assessee. They agreed with the CIT(A) that the assessee had misreported the turnover, attracting penalty provisions under Section 270A, and found no infirmity in the order.
The Tribunal held that corporate guarantee commission is an international transaction. Following its own previous decision, it directed that the commission should be charged at 0.50% on the corporate guarantee amount given to the AEs.