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Fresh Adjudication Ordered on TPO Adjustment in Subsidiary Transaction

March 9, 2025 84 Views 0 comment Print

Bangalore ITAT overturns AO’s PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and interest issues.

Entire Bank Transactions Cannot Be Treated as Turnover for Section 271B Penalty

March 8, 2025 3537 Views 0 comment Print

ITAT Surat remands penalty case under Section 271B to AO, ruling that bank transactions alone cannot determine turnover. Fresh consideration ordered.

AO can determine tax liabilities even during insolvency proceedings: ITAT Mumbai

March 8, 2025 177 Views 0 comment Print

ITAT Mumbai restores MITC Metals case for fresh adjudication, ruling that assessment order was not void ab-initio despite ongoing corporate insolvency proceedings.

Section 14A Explanation Applies Prospectively from 01/04/2022, Not Retrospectively

March 8, 2025 252 Views 0 comment Print

Explanation to Section 14A has only a prospective effect from April 1, 2022, and cannot be retrospectively applied to earlier assessment years.

ITAT Ahmedabad Dismisses Appeal Due to Assessee’s Non-Appearance

March 8, 2025 135 Views 0 comment Print

ITAT Ahmedabad dismisses Somnath Kelavni Mandal’s income tax appeal due to continuous absence in proceedings. Case pertains to unexplained cash deposits under Section 69A.

Section 43A not invocable when there is only reinstatement of fluctuation loss

March 8, 2025 216 Views 0 comment Print

ITAT Delhi held that provision of section 43A of the Income Tax Act not invocable when there is only reinstatement of fluctuation loss as per accounting standards and there is no actual payment or remittance. Thus, appeal allowed.

ITAT Deletes ₹12 Lakh Addition on Post-Demonetization SBN Deposits

March 8, 2025 411 Views 0 comment Print

ITAT Bangalore reverses addition of ₹12 lakh under Section 68, accepting sales as the source of cash deposits made during demonetization by Raju Rajesh.

2202-Day Delay in Income Tax Appeal Filing Condoned in Palmera Co-op Case

March 8, 2025 291 Views 0 comment Print

ITAT Mumbai condones a 2202-day delay in filing appeal by Palmera Co-op Housing Society. Bona fide belief in rectification under Section 154 upheld.

Indian Subsidiary Not a Dependent Agency PE if Transactions Are Subject to TPO Adjustment

March 8, 2025 192 Views 0 comment Print

ITAT Bangalore sets aside AO’s decision in Qlik Tech International AB vs DCIT, addressing PE classification, TDS credit, and tax refund interest disputes.

Section 69A Additions Based on Suspicion Without Evidence Deleted by ITAT

March 8, 2025 480 Views 0 comment Print

ITAT Chennai deletes additions under Section 69A for cash deposits made during demonetization by P. Tamilmani. Case highlights proper accounting and unjustified suspicions.

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