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Archive: 31 October 2025

Posts in 31 October 2025

FAQs on Section 80TTA and Section 80TTB deduction

October 31, 2025 7533 Views 0 comment Print

Know the differences between Sections 80TTA and 80TTB of the Income-tax Act. Learn eligibility, deduction limits of Rs.10,000 and Rs.50,000, applicable income sources, and rules under the new tax regime Section 115BAC.

SEBI Amends Mutual Fund Rules to Include REIT Units and Hike Limit

October 31, 2025 1083 Views 0 comment Print

SEBI’s latest amendment includes REIT units in mutual fund investment rules, raises the liquid scheme limit to 97%, and adjusts cross-holding restrictions for Specialized Investment Funds.

SEBI Amends Anchor Investor Rules in ICDR Regulations 2025

October 31, 2025 3768 Views 1 comment Print

SEBI’s new ICDR regulations revise anchor investor norms, setting minimum allotment limits and capping investor numbers. The rules also reserve 40% of the portion for domestic mutual funds, life insurers, and pension funds.

Rectification u/s 154 on Dropped Reopening Held Invalid – ITAT Delhi Quashes ₹3.56 Cr Addition

October 31, 2025 2313 Views 0 comment Print

The ITAT Delhi quashed a rectification order under Section 154, holding that a debatable issue regarding provision for construction expenses is not a “mistake apparent from record.” The ruling reinforces that Section 154 cannot be used to make additions that require a long-drawn process of reasoning or legal interpretation.

Processing Fee is Interest, Not FTS – ITAT Delhi Follows Earlier Year decision

October 31, 2025 831 Views 0 comment Print

The ITAT followed its earlier ruling for the German financial institution, confirming that the management/processing fee was a component of the loan financing and not a fee for technical services. The decision directed the deletion of the entire addition, reinforcing that the taxability of fees must be determined based on their underlying nature and link to the principal loan.

Software Cost Cross-Charge Not FIS/Royalty – ITAT Delhi Follows Earlier Year in SNC Lavalin Case

October 31, 2025 495 Views 0 comment Print

The Tribunal ruled that the cross-charged fee for use of third-party software does not qualify as Royalty as the payment is for a copyrighted article and not the transfer of copyright rights. This decision deletes a significant addition, reaffirming that the make available clause in the DTAA was not satisfied.

Cash Deposit Addition Scaled Down to 5% – ITAT Delhi Upholds CIT(A)’s Estimate

October 31, 2025 1143 Views 0 comment Print

The ITAT confirmed the CIT(A)’s pragmatic decision to restrict an addition of ₹8.21 crore for unexplained cash deposits to a 5% profit margin on the total deposits. This estimation was deemed reasonable, considering the nature of the assessee’s pottery trading business where full documentation was absent, balancing commercial reality with revenue protection.

PCIT’s Revision u/s 263 Quashed – ITAT Mumbai Rules AO’s Enquiry Was Adequate

October 31, 2025 495 Views 0 comment Print

The ITAT Mumbai quashed a revisionary order under Section 263, ruling that the Assessing Officer’s detailed scrutiny into the Rs.124 crore business loss was adequate.2 The Tribunal confirmed that when an AO conducts proper inquiries, the order is not “erroneous” and cannot be subject to revision merely because the PCIT disagrees.

Penny Stock LTCG Held Genuine – ITAT Mumbai Deletes ₹85.05 Lakh Addition

October 31, 2025 1086 Views 0 comment Print

The ITAT Mumbai deleted an addition of Rs.85.05 lakh, ruling that Long-Term Capital Gain (LTCG) on the sale of M/s Pine Animation Ltd. shares was genuine. The Tribunal held that demat-backed transactions through banking channels cannot be rejected merely based on a general Investigation Wing report.

PCIT’s 263 Revision Struck Down – ITAT Ahmedabad Quashes Order for Lack of Enquiry Finding

October 31, 2025 348 Views 0 comment Print

The ITAT allowed the assessee’s appeal, holding that the PCIT’s order under Section 263 was unsustainable because it failed to cite any specific instance where the AO neglected to verify the alleged fictitious loan transaction. For Section 263 to apply, both the error in the assessment and prejudice to the revenue must be proven, which the PCIT did not demonstrate.

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