The ITAT held that CSR expenditure disallowed as business expenditure under Section 37(1) can still qualify for deduction under Section 80G if statutory conditions are satisfied. Revision under Section 263 was accordingly quashed.
The ITAT held that unverified third-party excel sheets without corroborative evidence cannot justify additions under Sections 69 or 69A. The Tribunal observed that mere electronic entries amount to dumb documents unless independently verified.
The ITAT ruled that accepted sales necessarily imply corresponding purchases, even if sourced through the grey market. The addition was therefore restricted to estimated profit instead of the full purchase amount.
The Tribunal held that the AO wrongly aggregated actual property value and stamp duty valuation of the same transaction to invoke extended limitation under Section 149(1)(b). The reassessment notice for AY 2015-16 was declared time-barred and without jurisdiction.
The Mumbai ITAT held that no separate addition for alleged bogus purchases can be made where the assessee has already disclosed a higher gross profit on disputed transactions. The Tribunal relied on Bombay High Court rulings limiting additions only to differential GP.
Mumbai ITAT held that no further profits can be attributed to a DAPE once the Indian agent is remunerated at arm’s length for all FAR functions. The Tribunal rejected the Revenue’s “double profit attribution” theory and deleted the enhanced PE addition.
Pune ITAT held that interest earned by a co-operative credit society from deposits with co-operative banks qualifies for deduction under Section 80P(2)(d). The Tribunal clarified that the Supreme Court ruling in Totgars does not apply to such claims.
ITAT holds TDS applies on year-end provisions where payee, amount, and nature are identifiable—assessee treated in default u/s 201. Relief allowed if payees paid tax; no TDS default on salary provisions as deduction arises on payment.
ITAT allows Section 80P deduction to Souharda society, holding registration under Souharda Act qualifies as co-operative society; rejects technical denial, finds no non-member dealings, and rules even disallowances boosting income remain eligible for 80P deduction.
ITAT allows deduction of interest paid under capital bond agreement, holding a clear contractual obligation existed; since corresponding interest income was taxed, matching liability must be allowed-disallowance deleted as one-sided taxation is impermissible.
