ITAT Chennai held that neurology conferences and workshops squarely fall within the ambit of education under section 2(15) of the Income Tax Act. Hence, exemption under section 11 cannot be denied. Accordingly, appeal allowed.
ITAT Chennai held that since there was sufficient own funds to make investment/advances to its subsidiary, the interest disallowance under section 36(1)(iii) was not warranted. Accordingly, AO directed to delete the addition.
ITAT Mumbai held that courses not having any approval or affiliation with any authority cannot be ground to hold that the purpose is not charitable. Accordingly, benefit of exemption under section 11 of the Income Tax Act granted since activity of imparting education within meaning of section 2(15).
The Tribunal held that late filing of Form 10-IC does not bar concessional tax benefits under Section 115BAA. The assessing officer was directed to allow relief once conditions are met.
Tribunal clarified that the Section 251 amendment uses the term ‘may set aside,’ meaning it is discretionary. Since the issue was already resolved in remand, addition was deleted.
Assessments on foreign-sourced income were deleted after the ITAT confirmed the assessee’s Non-Resident status under Explanation 1(a) of Section 6(1).
Tribunal held that denying opportunity to submit evidence amounts to potential miscarriage of justice. CIT(A) directed to reconsider income addition after evaluating all documents.
ITAT held that appeals filed with incorrect jurisdiction cannot be heard. All four appeals dismissed, but assessee allowed to refile before correct bench.
ITAT ruled that Section 201 proceedings initiated beyond four years are legally untenable. Since the 201(1) order for AY 2016-17 was issued after the limitation period, the entire TDS demand was deleted. Tribunal held that date of knowledge is irrelevant for limitation.
The Tribunal held that ad agencies operate on low margins, and without comparables, an 8% estimate was excessive. Past history was accepted as the best guide, reducing profit estimation to 5% and deleting cash-deposit addition as double counting.
