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ITAT dismissed Revenue's appeal on multiple grounds. AO's adoption of Rs. 3,000/sq.ft. as commercial space sale price was rejected due to lack of concrete evidence beyond mere statements. The tribunal upheld CIT(A)'s decision on reimbursement of expenditure, following precedent that Revenue cannot take contrary positions among group assessees. Addition for out-of-court settlement amount was deleted as it would result in double taxation since Rs. 83 lakhs was already declared as income. Regarding expenditure on commercial space sale, CIT(A)'s deletion of addition was sustained as expenses were properly documented through banking channels. Revenue's objection about remand report was dismissed as available evidence was sufficient for determination.
ITAT dismissed Revenue's appeal on multiple grounds. AO's adoption of Rs. 3,000/sq.ft. as commercial space sale price was rejected due to lack of concrete evidence beyond mere statements. The tribunal upheld CIT(A)'s decision on reimbursement of expenditure, following precedent that Revenue cannot take contrary positions among group assessees. Addition for out-of-court settlement amount was deleted as it would result in double taxation since Rs. 83 lakhs was already declared as income. Regarding expenditure on commercial space sale, CIT(A)'s deletion of addition was sustained as expenses were properly documented through banking channels. Revenue's objection about remand report was dismissed as available evidence was sufficient for determination.
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