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U/s 80P claim closed, but cost of funds gets second chance: ITAT remands Sec 57 issue

March 27, 2026 324 Views 0 comment Print

The Tribunal held that deduction under Section 80P on bank interest cannot be re-examined once earlier order attained finality. The issue was restricted to allowing related expenses under Section 57.

Delayed ITR verification ≠ denial of 80P: ITAT allows deduction

March 27, 2026 597 Views 0 comment Print

The Tribunal held that delayed verification of an e-filed return is only a procedural lapse. Deduction under Section 80P cannot be denied when the return was filed within the due date.

U/s 80P wins despite disallowance: ITAT calls interest provision issue tax-neutral for co-op society

March 27, 2026 357 Views 0 comment Print

The Tribunal held that disallowance of interest provision only increases business income, which remains eligible for Section 80P deduction. Hence, the addition was treated as tax-neutral and not taxable.

No bills ≠ bogus: Bangalore ITAT deletes Sec 69A addition on agricultural income

March 27, 2026 1542 Views 0 comment Print

The Tribunal held that absence of bills for agricultural sales cannot justify addition under Section 69A. Where cultivation and land ownership are undisputed, receipts cannot be treated as unexplained income.

Section 54F Allowed Even When Property Purchased in Sister’s Name – Subsequent Gift Validates Claim

March 24, 2026 936 Views 0 comment Print

DCIT Vs Revanth Challagalla (ITAT Hyderabad) Section 54F Allowed Even When Property Purchased in Sister’s Name – Subsequent Gift Validates Claim In this case, the ITAT Hyderabad upheld the allowance of deduction under Section 54F despite the property being initially registered in the name of the assessee’s sister. The assessee, an NRI, had sold villas […]

Condonation of Delay Requires Fair Opportunity – ITAT Remands Matter Despite 18-Month Delay

March 24, 2026 459 Views 0 comment Print

The issue was whether delay of 18 months could be rejected without proper opportunity. The ITAT held that fair hearing is essential and remanded the matter for reconsideration of delay with supporting evidence.

Delay in Filing Appeal Should Be Liberally Condoned When Sufficient Cause Exists – ITAT Bangalore

March 24, 2026 531 Views 0 comment Print

The issue was whether delay in filing appeal without strong documentary proof should be condoned. The ITAT held that when sufficient cause exists, delay must be liberally condoned to ensure justice and hearing on merits.

Protective Additions Cannot Survive Once Substantive Addition Fails – ITAT Bangalore in Trust Search Cases

March 24, 2026 366 Views 0 comment Print

The issue was whether protective additions can survive when substantive additions are deleted. The ITAT held that once the substantive addition fails on merits, the protective addition based on the same material cannot be sustained.

No Capital Gains on JDA Amid Family Dispute; Additions Based on Statement Alone Unsustainable – ITAT Bangalore

March 24, 2026 594 Views 0 comment Print

The issue was whether a Joint Development Agreement (JDA) constituted transfer triggering capital gains. The tribunal held no taxable transfer occurred as rights were unsettled due to partition disputes and lack of finality.

ITAT Mumbai: No U/s 36(1)(iii) Disallowance If Own Funds Exceed Advances

March 23, 2026 609 Views 0 comment Print

ITAT held that where interest-free funds exceed advances, a presumption arises that such advances are made from own funds. Disallowance under section 36(1)(iii) was deleted as no nexus with borrowed funds was proven.

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