The Bangalore ITAT ruled that once substantive addition under Section 2(22)(e) is sustained in the managing partners case, the corresponding protective addition in the firm’s hands must be deleted. The ruling clarifies that protective assessments are only temporary safeguards.
The Hyderabad ITAT ruled that the CIT(A) could not delete unexplained cash deposit additions merely on the basis of submissions and audit reports without supporting documents proving business transactions.
The ITAT Ahmedabad held that co-operative banks qualify as co-operative societies for purposes of Section 80P(2)(d). The Tribunal allowed deduction on interest income earned from deposits with co-operative banks following Gujarat High Court rulings.
The ITAT held that credits received in the assessee’s bank account were repayments of earlier advances and not unexplained cash credits. The Tribunal deleted the addition after finding that the transactions were supported by bank records and financial documents.
Tribunal ruled that income tax demands not included in the approved resolution plan were irrevocably extinguished. The decision followed the terms of the NCLT-approved insolvency resolution plan restored by the Supreme Court.
TAT Chandigarh held that reassessment proceedings were invalid because the property was actually purchased from a different company than the one referred to in the recorded reasons. The Tribunal found absence of any live nexus between the assessee and the alleged incriminating material.
ITAT Mumbai held that disallowance computed under Section 14A cannot be directly added while computing book profits under Section 115JB. Matter was remanded for fresh computation following the Vireet Investment ruling.
The Kolkata ITAT deleted an addition against an employees gratuity fund after finding that gratuity payments were higher than the interest income earned during the year. The Tribunal held that excess expenditure over income meant no taxable addition could survive.
The ITAT Agra held that cash deposits could not be treated as unexplained where the assessee had already disclosed commission income in the income tax return. The Tribunal granted relief after finding that the Assessing Officer failed to consider the declared income source.
The ITAT Visakhapatnam held that a reassessment notice issued after expiry of six years for AY 2015-16 was barred by limitation under the first proviso to Section 149(1). The Tribunal ruled that the amended ten-year reopening period could not revive time-barred cases.
