The Tribunal relied on Supreme Court rulings to hold that co-operative banks qualify as co-operative societies for deduction purposes. It allowed deduction on interest income under Section 80P(2)(d).
ITAT Chennai held that reassessment u/s. 148 of the Income Tax Act after expiry of four years not sustainable since there was no failure on the part of assessee to disclose fully and truly all material facts. Further, reassessment is invalid for non-furnishing of actual reasons recorded.
The Tribunal held that entire TDS credit can be allowed to one co-owner if the other has not claimed it. It remanded the matter for verification to prevent double credit.
The Tribunal examined whether reassessment proceedings were valid when initiated beyond the statutory time limit. It held that the notice issued under Section 148 was barred by limitation and invalid. The ruling emphasizes strict adherence to limitation provisions in reassessment cases.
The ITAT held that no addition can be made under Section 69A when the source of cash is explained through bank withdrawals. Doubts about utilisation alone cannot justify treating it as unexplained money.
The Tribunal examined denial of exemption under Sections 11 and 12 due to delayed filing of audit reports. It held that the delay overlapped with COVID-19 disruptions and required reconsideration. The matter was remanded for fresh adjudication based on condonation outcome.
The Tribunal held that commission income cannot be computed on internal or circular banking transactions. It reduced the commission rate from 1.75% to 0.47% and directed recomputation after verification. The ruling emphasizes accurate determination of real in-come.
The Tribunal held that interest earned by a co-operative society from deposits with co-operative banks qualifies for deduction under Section 80P(2)(d). It clarified that co-operative banks are also co-operative societies for this purpose.
ITAT Chennai held that the excess payment over the net book value of assets and liabilities acquired on account of amalgamation is in the nature of ‘goodwill’ and is eligible for depreciation u/s.32(1)(ii) of the Income Tax Act.
The ITAT held that revision under Section 263 cannot be invoked where the Assessing Officer has conducted detailed inquiries and adopted a plausible view. The Tribunal ruled that a mere change of opinion by the PCIT does not render the assessment order erroneous or prejudicial.
