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U/s 80P Deduction Denied for Belated Return Post-2018 Amendment – ITAT Hyderabad Upholds Disallowance

April 15, 2026 615 Views 0 comment Print

The issue was whether deduction under Section 80P is allowed when return is filed late. ITAT held that post-2018 amendment, deduction is barred if return is not filed within the due date under Section 139(1).

ITAT Hyderabad: Foreign Tax Relief Must Be Deducted While Computing Interest U/s 234A/B/C

April 15, 2026 447 Views 0 comment Print

The issue was incorrect computation of interest without reducing foreign tax relief. ITAT held that relief under sections 90/90A must be deducted before calculating interest under sections 234A, 234B, and 234C.

ITAT Rajkot: Addition Based on ‘Dump Excel Sheet’ Deleted – No Evidence, No Tax

April 14, 2026 1326 Views 0 comment Print

The Tribunal held that unsigned excel sheets without supporting evidence cannot justify additions. It ruled that absence of corroboration and cross-examination renders such documents unreliable.

LTCG Addition Deleted as No Evidence Linking Assessee to Penny Stock Manipulation: ITAT Delhi

April 14, 2026 3198 Views 0 comment Print

The Tribunal held that mere classification of shares as penny stock is insufficient to deny LTCG exemption. In absence of evidence linking the assessee to manipulation, the addition under Section 69A was deleted.

ESOP Discount Allowed as Revenue Expense: ITAT rejects Notional Loss Claim

April 14, 2026 399 Views 0 comment Print

The Tribunal upheld deduction of ESOP expenses, relying on earlier decisions in the same case. It ruled that no change in facts justified a different view.

Addition on FD Interest Remanded as Authorities Failed to Examine Mutuality Principle

April 14, 2026 447 Views 0 comment Print

The Tribunal found that the assessee was not given adequate opportunity to present its case. It set aside the order and directed fresh assessment after proper hearing.

ITAT Remands Case as 12A and 80G Registration Denied Without Fair Opportunity

April 14, 2026 588 Views 0 comment Print

The Tribunal held that applications were rejected without adequate opportunity. The matter was remanded for fresh adjudication following natural justice.

ITAT Rajkot: Hybrid Seed Company’s Income Held as Agricultural

April 14, 2026 306 Views 0 comment Print

The issue was whether income from hybrid seed production on leased land qualifies as agricultural income. The Tribunal held that ownership is not necessary if the assessee exercises control, bears risk, and performs agricultural operations.

Cost-to-Cost Reimbursements allowed Due to Adequate Evidence, But Ad Expenses Disallowed for Lack of Proof

April 14, 2026 441 Views 0 comment Print

The Tribunal upheld cost-to-cost reimbursements for personnel and IT expenses where documentation and business purpose were established. However, advertisement expenses were disallowed due to absence of supporting evidence.

ITAT Allowed TDS Credit Despite Form 26AS Mismatch as Income Taxed in Same Year

April 14, 2026 684 Views 0 comment Print

The Tribunal held that TDS credit must be granted in the year in which the related income is assessed, even if it is not reflected in Form 26AS. The case clarifies that timing differences by the deductor cannot deny rightful credit.

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