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Additional Depreciation Granted as Oil Extraction Equals Production

December 17, 2025 288 Views 0 comment Print

The tribunal held that every oil well constitutes an independent undertaking eligible for deduction under section 80IB(9). The key takeaway is that profits of individual wells cannot be clubbed merely because they operate under a single contract.

Transfer Pricing Assessments Quashed as Time-Barred Despite DRP Directions

December 17, 2025 699 Views 0 comment Print

The tribunal held that assessments completed through the DRP mechanism remain subject to the outer time limit prescribed under section 153. The key takeaway is that section 144C does not extend or override statutory limitation periods.

ITAT Clarifies 80P Deduction on Deposited Funds of Cooperative Societies

December 17, 2025 630 Views 0 comment Print

ITAT Bangalore ruled that interest earned on deposits from cooperative banks by credit societies is attributable to their business of lending and qualifies for deduction under Section 80P(2)(a)(i).

Credit Society Entitled to Full U/s 80P Deduction on Deposit Interest

December 17, 2025 420 Views 0 comment Print

ITAT Bangalore ruled that interest earned by cooperative societies from cooperative bank deposits is attributable to their business of providing credit and qualifies for deduction under Section 80P(2)(a)(i).

Six Years of Reassessments Remanded for De-Novo Consideration

December 17, 2025 351 Views 0 comment Print

A 284-day delay in filing appeals was condoned after accepting explanations including medical issues and disruptions. The key takeaway is that relief was granted but balanced by imposing costs to deter repeated non-compliance.

NRI Cash Gift Addition Under Section 68 Remanded by ITAT Chennai

December 17, 2025 276 Views 0 comment Print

ITAT Chennai remanded a case involving Rs. 11.26 lakh cash gifts back to the CIT(A), allowing the NRI assessee another opportunity to substantiate the claim with supporting documents.

No Further Section 14A Disallowance After Reasoned Suo-Motu Adjustment

December 16, 2025 627 Views 0 comment Print

The ITAT held that where investments are fully backed by substantial own funds and a rational suo-motu disallowance is made, Rule 8D cannot be mechanically invoked. The Revenue’s attempt to make an additional disallowance was rejected.

ITAT Hyderabad quashes final TP assessment as time-barred despite DRP directions

December 16, 2025 723 Views 0 comment Print

The Tribunal held that limitation under Section 153 overrides the DRP timeline under Section 144C. As the assessment was completed beyond the statutory outer limit, it was quashed as invalid.

Delay in Filing Appeals Condoned Despite Massive Additions and Penalty

December 16, 2025 1029 Views 0 comment Print

While restoring the appeals, the ITAT directed expeditious disposal and warned against avoidable adjournments. The key takeaway is that condonation is granted to enable justice, not to prolong litigation.

Capital Gains Addition Set Aside for Denial of Fair Opportunity

December 16, 2025 504 Views 0 comment Print

The Tribunal held that an ex-parte capital gains addition could not be sustained where the assessee was denied a meaningful opportunity. Considering comparable treatment in a related case, the matter was remanded for fresh adjudication on merits.

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