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No Double Deduction: ITAT Allows Separate Claims for Bad Debts – Sections 36(1)(vii) & 36(1)(viia)

October 26, 2025 633 Views 0 comment Print

The Mumbai ITAT upheld the deletion of a disallowance for bad debts, confirming that deductions under Sections 36(1)(vii) and 36(1)(viia) are independent. The ruling followed the Supreme Court’s precedent, allowing the entire bad debt written off since no double deduction was claimed.

No prosecution u/s 276C for delayed tax payment without wilful evasion: Madras HC

October 24, 2025 5652 Views 0 comment Print

Madras HC: Delayed self-assessment tax payment is not ‘wilful evasion’ under IT Act S. 276C(2) if the tax is paid before prosecution. Mens rea is mandatory.

ITAT Quashes ₹16.48 Cr TP Adjustment on Negative Lien vs. Guarantee

October 17, 2025 336 Views 0 comment Print

Delhi ITAT ruled that a negative lien is not a corporate guarantee, quashing the Rs.16.48 Cr transfer pricing adjustment under Section 92B. Negative lien imposes no repayment liability.

eBay Singapore eligible for DTAA benefit as STCG on sale of Flipkart Singapore’s shares not taxable in India: ITAT Mumbai

October 16, 2025 660 Views 0 comment Print

Mumbai ITAT rules capital gains on a foreign company’s share sale are non-taxable in India under Article 13(5) of the India-Singapore DTAA. TRC is conclusive proof.

ITAT Jaipur Upholds Bogus Loan Additions, Slams Assessee’s Counsel for Misconduct

October 12, 2025 963 Views 0 comment Print

The ITAT Jaipur sustains additions under Sec. 68 for bogus unsecured loans in Bagaria Trade Impex case, rejecting technical relief and confirming the assessee failed to prove creditor genuineness.

ITAT Delhi Quashes Reopening Based on Bogus Purchases for Being Time-Barred

October 11, 2025 4479 Views 0 comment Print

ITAT Delhi rules Section 148 notice invalid as escaped income not represented in an ‘asset’; reassessment quashed for being time-barred.

Production of directors not mandatory to prove genuineness of transaction; Deletes commission addition: ITAT Delhi

September 29, 2025 318 Views 0 comment Print

ITAT Delhi held that production of investor directors is not mandatory to prove genuineness of share capital. Additions under Section 68 and presumed 2% commission were deleted.

Receipt for sale of copyrighted IFE video/audio content, not royalty: ITAT Delhi

September 24, 2025 255 Views 0 comment Print

The ITAT Delhi ruled that a UK company’s receipts from Indian airlines for in-flight content are not taxable as royalty or fees for technical services, as no copyright or technical know-how was transferred.

Gujarat HC Quashes Income Tax reassessment for Ignoring Taxpayer Submissions

September 24, 2025 636 Views 0 comment Print

Gujarat HC set aside an income tax reassessment order after the AO failed to consider the taxpayer’s detailed reply, emphasizing adherence to natural justice principles.

ITAT Mumbai Rejects Carry Forward Loss Due to 10-Day Delay Despite Medical Hardship

September 23, 2025 435 Views 0 comment Print

Tribunal rules that Mtitanium Apartments cannot claim ₹1.10 crore brought forward business losses as the income tax return for AY 2023-24 was filed late, despite medical hardship.

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