ITAT issues various rulings on Indian income tax assessments

The Income Tax Appellate Tribunal (ITAT) has issued several rulings across various Indian jurisdictions regarding tax assessments and the application of the Income-tax Act, 1961.

In Mumbai, the ITAT ruled that an entire property price cannot be added as an unexplained investment under Section 69 in a single year if payments were made over several years. In another Mumbai case, the Tribunal deleted a tax addition, ruling that the 10% tolerance band for differences between stamp duty value and purchase price is curative and applies retrospectively.

In Delhi, the Tribunal held that an independent royalty agreement cannot be benchmarked as a related-party transaction without evidence of an associated-enterprise relationship. Additionally, the Delhi ITAT dismissed a revenue appeal, stating that the low income of lenders alone is insufficient to justify additions under Section 68 if identity and creditworthiness are established.

In Chandigarh, the ITAT ruled that excess stock found during a survey should be assessed as business income at normal rates rather than as unexplained investment under Section 69B.