Judgement

Judicial discipline mandates adherence to jurisdictional ITAT decisions; PCIT directed to pass fresh order in line with Special Bench ruling.

High Court Quashes Section 264 Order, Reaffirms Binding Nature of ITAT Special Bench Rulings

The ITAT holds that purchases supported by invoices, transport documents, bank payments, and matching sales cannot be treated as bogus solely due to a supplier’s non-response, rejecting additions under Section 69C

Purchases Supported by Invoices, Transport Documents and Bank Payments Cannot Be Held Bogus Merely Due to Supplier’s Non-Response: ITAT

ITAT rules that CPC cannot invoke Section 50C while processing returns without DVO reference, holding such adjustments to be illegal.

ITAT Delhi Holds Section 50C Adjustment Not Permissible at 143(1) Processing Stage

Tribunal held that 100% disallowance of FTS payments to non-residents under Section 40(a)(i) is discriminatory under Article 26(3) of the India-USA DTAA.

ITAT Delhi Quashes Section 263 Revision on 100% Disallowance of FTS to Non-Residents

Seized handwritten ledgers treated as reliable evidence of unexplained expenditure; Revenue succeeds on interest addition

ITAT Ahmedabad Confirms Section 69C Additions Based on Seized Diaries

Consistency with earlier years upheld as ITAT rejects separate benchmarking of AMP expenditure; partial relief granted on interest and other disallowances

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High Court Quashes Section 264 Order, Reaffirms Binding Nature of ITAT Special Bench Rulings

Purchases Supported by Invoices, Transport Documents and Bank Payments Cannot Be Held Bogus Merely Due to Supplier’s Non-Response: ITAT

ITAT Delhi Holds Section 50C Adjustment Not Permissible at 143(1) Processing Stage

ITAT Delhi Quashes Section 263 Revision on 100% Disallowance of FTS to Non-Residents

ITAT Ahmedabad Confirms Section 69C Additions Based on Seized Diaries

AMP Spend Not Separate International Transaction: ITAT Grants Relief to Pharma Major