ITAT Delhi emphasized that FAR analysis governs segmentation for transfer pricing purposes. Artificial aggregation without ...
The Tribunal ruled that unexplained money provisions cannot be applied on conjectures when the source of cash is reasonably explained. With no dispute on withdrawals and savings, the ...
The Tribunal ruled that CIT(A) must pass a speaking order addressing all grounds raised. Failure to do so vitiates the appellate order, regardless of assessee’s ...
The SAFEMA Appellate Tribunal held that property attachment under PMLA requires prima facie proof of a money trail. Mere suspicion or association with accused persons is insufficient to sustain ...
The Tribunal held that a bad debt claim involving factual and legal analysis cannot be disallowed during section 143(1) processing. Such issues must be examined through regular assessment proceedings, ...
The Tribunal considered reliance on investigation wing inputs alleging non-genuine entities. It ruled that adverse material must be shared with the assessee and corroborated through proper enquiry ...
This case dealt with an addition confirmed without adequate opportunity of hearing. The Tribunal held that passing an order without considering filed replies is unsustainable, and directed a de novo ...
The issue was whether interest received on enhanced compensation for compulsory land acquisition is exempt from tax. The Tribunal held that after the 2010 amendment, such interest is taxable as income ...
The Tribunal examined whether non-deduction of TDS on External Development Charges justified treating the payer as an assessee-in-default. It held that the Assessing Officer must first verify whether ...
The Tribunal reaffirmed that revision cannot be exercised merely because the PCIT holds a different view. When the Assessing Officer’s view is plausible and based on enquiry, the assessment cannot be ...
The Tribunal examined whether an assessment ignoring a clear mismatch between turnover and TCS data could survive. It held that absence of enquiry on such discrepancy renders the order erroneous and ...
The Tribunal ruled that an appellate authority cannot dismiss an appeal solely for non-compliance and must decide it on merits, leading to remand for fresh ...
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