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ITAT Pune: Interest on Bank Deposits Not Covered by Mutuality; Only Proportionate Expenses Allowed

April 13, 2026 351 Views 0 comment Print

ITAT held that interest earned on bank deposits is taxable and not covered by the principle of mutuality. The ruling confirms that dealings with third parties break mutuality protection.

ITAT Mumbai: Reopening Invalid on Change of Opinion-No Fresh Material, Assessment Quashed

April 13, 2026 360 Views 0 comment Print

ITAT held reassessment invalid as it was based on already examined facts without fresh material. The ruling reinforces that reopening on mere change of opinion is not permissible.

Deemed Dividend Upheld, But AO Directed to Recompute After Interest Adjustment: ITAT Pune

April 13, 2026 240 Views 0 comment Print

The Tribunal ruled that even temporary withdrawals by a shareholder can trigger deemed dividend under Section 2(22)(e). It held that duration or repayment does not negate taxability.

Procedural Lapse Cannot Deny U/s 12A Registration: ITAT Pune

April 13, 2026 258 Views 0 comment Print

The Tribunal ruled that failure to obtain prior approval for loans is only a procedural lapse. It directed reconsideration of 12A registration after acknowledging genuine charitable activities.

ITAT Mumbai: Second Reopening Based on Same Material Is Invalid-Change of Opinion Not Permissible

April 13, 2026 366 Views 0 comment Print

The Tribunal ruled that reassessment cannot be reopened on issues already examined earlier. It held that absence of fresh material and mere change of opinion renders reopening invalid.

ITAT Mumbai Allows Actuarial Provisions for Employee Benefit Schemes; Deletes Major Disallowances on Expense Provisions

April 13, 2026 426 Views 0 comment Print

ITAT Mumbai rules actuarial provisions for employee benefit schemes are allowable under Section 37(1) as ascertained liabilities, deletes major disallowances on expense provisions, limits TDS applicability to payment stage, and prevents double taxation of expenses.

ITAT Mumbai: Sec 14A Disallowance Cannot Exceed Exempt Income-Addition Restricted

April 13, 2026 423 Views 0 comment Print

ITAT Mumbai rules that Section 14A disallowance cannot exceed exempt income, directing AO to cap disallowance accordingly and delete excess addition, granting relief to assessee.

ITAT Mumbai: Reopening Invalid Without Proper Sanction-Approval by Wrong Authority Vitiates Entire Proceedings

April 13, 2026 450 Views 0 comment Print

ITAT Mumbai holds reassessment invalid where approval under Section 151 was obtained from incorrect authority, ruling defect as jurisdictional and quashing notice under Section 148 and consequent proceedings.

ITAT Mumbai: Interest from Co-Operative Banks Eligible U/s 80P(2)(d)-Consistency Principle Applied

April 13, 2026 318 Views 0 comment Print

The Tribunal held that interest earned from deposits with co-operative banks is eligible for deduction under Section 80P(2)(d). It clarified that co-operative banks are treated as co-operative societies for this purpose.

ITAT Mumbai: Reopening Beyond 3 Years Invalid Where Escaped Income below ₹50L-Notice u/s 148 Quashed

April 13, 2026 459 Views 0 comment Print

ITAT Mumbai quashes reopening beyond 3 years where escaped income is below ₹50 lakh, holding notice under Section 148 time-barred and invalid, thereby deleting consequential addition.

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