ITAT Bangalore held that at the relevant time co-founder of Flipkart stayed in India for 141 days and balance days in other countries. Hence, assessee is an Indian national and thus the appeal of the assessee is dismissed.
ITAT Mumbai held that disallowance of interest expenditure under Rule 8D(2)(ii) of the Income Tax Rules is not sustainable since the assessee’s own interest-free funds were substantially higher than the investment. Accordingly, appeal of revenue dismissed and order of CIT(A) upheld.
The ruling addressed whether a delayed application could survive after statutory change. The Tribunal directed fresh consideration by applying the liberalized timeline introduced by Finance Act, 2024.
ITAT Chennai held that merely opting for Vivad-Se-Vishwas does not end an appeal unless settlement is completed; dismissal by assumption was invalid and appeal was restored for merits adjudication.
ITAT Chennai held that once delay in filing return is condoned under section 119(2)(b), CPCs denial of deduction under section 80P collapses and relief must be granted.
The tribunal held that a purchase cannot be treated as bogus solely based on third-party allegations. Without independent verification by the Assessing Officer, the disallowance was held unsustainable.
The tribunal held that interest earned from deposits with co-operative banks qualifies for deduction under Section 80P(2)(d). Such banks are treated as co-operative societies, making the interest fully deductible.
The tribunal held that amounts already disclosed and taxed as accommodated receipts cannot be taxed again under another head. Separate additions were deleted as they resulted in impermissible double taxation.
The tribunal held that interest earned on savings bank deposits is attributable to the business of providing credit to members. Such incidental bank interest qualifies for full deduction under Section 80P(2)(a)(i).
The issue was whether reassessment completed after a court stay complied with statutory timelines. The Tribunal held that limitation resumes from the date the stay is vacated, rendering the reassessment time-barred.
