Circular Transactions within Group Entities not Considered Income for Assessee: ITAT

The Income Tax Appellate Tribunal (ITAT) ruled that circular transactions within group entities should not be considered income for the assessee. The case involved an assessee who had engaged in circular transactions with its group entities, which the tax authorities had treated as income. The ITAT found that these transactions did not constitute real income and should not be taxed. This ruling clarifies the treatment of intra-group transactions for tax purposes and supports the principle of substance over form in tax assessments.