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Archive: December, 2025

Posts in December, 2025

Section 153(3)(ii) Prevails Over Section 153(2A) in Special Audit Cases: ITAT Lucknow

December 23, 2025 285 Views 0 comment Print

The ruling clarifies that Section 153(3)(ii) operates as an exception to the normal limitation framework. When assessments are made to give effect to appellate directions involving special audits, no fixed time limit applies.

Provision of future expense allowed as deduction u/s. 37(1) based on matching principle of accountancy

December 23, 2025 798 Views 0 comment Print

ITAT Jaipur held that claim on account of provision of future expense is allowable under section 37(1) of the Income Tax Act as per matching principle of accountancy. Accordingly, appeal is allowed.

Bhagavad Gita, Vedanta & Yoga Are Philosophical and Not Religious: Madras HC

December 23, 2025 4506 Views 0 comment Print

The court held that valid registration under income-tax law is a relevant factor under FCRA and cannot be ignored. Failure to consider it violated Section 52, which makes FCRA supplementary to other laws.

Unified Pension Scheme Rules Amended to Add One-Time Switch to NPS

December 23, 2025 645 Views 0 comment Print

The amendment introduces a one-time option for UPS subscribers to revert to NPS within defined service timelines. The key takeaway is added flexibility, with clear conditions on contributions and loss of assured UPS benefits after switching.

Ex-parte Enhancement Without Notice Unsustainable: ITAT ITAT Bangalore

December 23, 2025 822 Views 0 comment Print

The Tribunal ruled that increasing assessed income without issuing a notice under section 251 violates natural justice. The case was remanded as ex-parte enhancement beyond the original addition was found legally unsustainable.

CPC Cannot Deny Section 10(23C)(iiiad) Exemption via Section 143(1) Adjustments ITAT Bangalore

December 23, 2025 909 Views 0 comment Print

Tribunal held that debatable issues fall outside scope of summary adjustments under section 143(1). Denial of exemption based on procedural lapses was therefore unsustainable.

ITAT Bangalore: Section 148 Valid, Reassessment Set Aside for Non-Supply of Reasons

December 23, 2025 675 Views 0 comment Print

ITAT Bangalore invalidated a reassessment where the assessee was not provided the recorded reasons, emphasizing that reopening notices must be supported by clear, communicated reasons before filing returns.

Later-Year Depreciation Cannot Be Decided Until Base Year Cost Is Finalised: ITAT Bangalore

December 23, 2025 294 Views 0 comment Print

The Tribunal ruled that depreciation for subsequent years is consequential to the first-year determination of actual cost. Appeals were restored as the base year issue remained undecided.

Routine Repairs & Maintenance Allowed as Revenue Expense Due to No Enduring Benefit

December 23, 2025 546 Views 0 comment Print

The Tribunal ruled that routine replacement of plant and machinery parts does not create a new asset or enduring benefit. Such expenses were held to be revenue in nature and fully deductible.

ITAT Bangalore Allows 80P Deduction on Interest From Co-operative Banks; 307-Day Delay Condoned

December 23, 2025 783 Views 0 comment Print

ITAT Bangalore ruled that interest earned by a cooperative society from bank deposits is attributable to its core business and eligible for deduction under Section 80P(2)(a)(i), reversing the denial by lower authorities.

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