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TP Adjustment Deleted as INR-Denominated CCD Interest Must Follow PLR

December 18, 2025 612 Views 0 comment Print

The issue was whether interest on INR-denominated CCDs should be benchmarked using LIBOR or domestic rates. The Tribunal held that PLR applies, rendering the transfer pricing adjustment unsustainable.

ITAT Chennai Condones 45-Day Delay; NFAC Cannot Reject Appeal In-Limine When Cause Is Reasonable

December 18, 2025 213 Views 0 comment Print

The issue was whether a short delay in filing an appeal justified outright dismissal. The Tribunal held that illness supported by medical evidence constituted reasonable cause and restored the appeal for merits adjudication.

Section 263 Revision Unwarranted After Due Inquiry; Revenue Appeal Dismissed

December 18, 2025 675 Views 0 comment Print

The ITAT dismissed the Revenue’s appeal after the High Court upheld that revision under Section 263 was unwarranted where the Assessing Officer had conducted due inquiry.

Loss on Loan-to-Equity Conversion Allowed as Business Loss to Bank: ITAT Mumbai

December 18, 2025 720 Views 0 comment Print

Tribunal held that loss arising from compulsory conversion of stressed loans into equity under a restructuring scheme is a deductible business loss or bad debt for a bank.

Milk Procurement Incidental to Charitable Object; Section 11 Exemption Allowed

December 18, 2025 381 Views 0 comment Print

The tribunal held that milk procurement and sale by a charitable society were incidental to its primary object of helping small and marginal farmers, and exemption under Section 11 could not be denied.

Amended Section 115BBE Rate Not Applicable Retrospectively on Section 69A Addition

December 18, 2025 1713 Views 0 comment Print

The assessee claimed the firm had dissolved and deposits belonged to a partner. The Tribunal held that absence of documentary proof justified treating bank deposits as unexplained income.

Difference of Opinion Not Enough to Invoke Revisionary Jurisdiction: ITAT Mumbai

December 18, 2025 489 Views 0 comment Print

The issue was whether a completed assessment could be revised without identifying concrete errors. The Tribunal held that vague observations and absence of specific defects do not justify invoking section 263.

Section 80P Deduction Allowed as Co-operative Bank Treated as Co-operative Society

December 18, 2025 813 Views 0 comment Print

The Tribunal held that interest earned from investments with a co-operative bank registered as a co-operative society qualifies for deduction under Section 80P(2)(d), following jurisdictional High Court rulings.

Income Tax Assessment Quashed Due to Manual Signature in E-Proceedings: ITAT Delhi

December 18, 2025 11481 Views 0 comment Print

The tribunal ruled that an assessment order signed manually instead of digitally in e-proceedings violates binding CBDT instructions and is legally void.

Section 144 Assessment Quashed for Failure to Issue Mandatory Section 143(2) Notice

December 18, 2025 1317 Views 0 comment Print

The tribunal examined whether an assessment under section 144 could survive without issuance of a notice under section 143(2). It held that non-issuance of the mandatory notice rendered the assessment void ab initio.

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