The ITAT held that notices issued only through the ITBA Portal did not constitute valid service under the Income-tax Act and Rules. It remanded the Section 12AB application for fresh consideration after granting a proper hearing.
The ITAT held that CSR expenditure disallowed under Section 37(1) does not automatically bar deduction under Section 80G where statutory conditions are fulfilled. It allowed the deduction for donations made to an eligible Section 80G-registered trust.
The ITAT accepted kidney-related medical treatment and renal transplant as sufficient cause for a 375-day delay in filing the appeal. It remanded the agricultural income addition to the Commissioner (Appeals) for fresh adjudication after granting an opportunity of hearing.
The ITAT Chennai held that exemption under Section 10(23FBA) cannot be denied merely by reclassifying investment returns as business income without proper analysis. It found that the Assessing Officer failed to apply recognised tests for determining the nature of income.
The ITAT held that foreign exchange gains arising from realization of export proceeds from services rendered to associated enterprises are operating in nature for transfer pricing purposes. It directed verification by the Assessing Officer and corresponding computation of the arm’s length margin.
The ITAT held that Section 69A could not be invoked as the director was not the owner of the unaccounted cash generated through over-invoicing. The Tribunal upheld deletion of the addition while affirming that the company owned the cash.
The ITAT Delhi held that the assessee could not claim deduction under Section 54 for the first time before the Tribunal when it had neither been claimed in the return nor during assessment proceedings. The Tribunal also upheld the remand of the Section 50C issue to the Assessing Officer.
The ITAT dismissed the appeal after finding that the appeal fee was paid under an incorrect head and the 754-day delay remained unexplained. The Tribunal held that the defects were not cured and no condonation petition was filed.
ITAT Delhi held that cash deposits recorded in audited books and linked to disclosed business transactions could not be taxed under Section 69A. The Tribunal deleted the ₹5.60 crore addition after finding the source of deposits was explained.
ITAT Mumbai held that Compulsorily Convertible Debentures could not be treated as equity merely to deny interest deductions. The Tribunal deleted the ₹76.45 crore transfer pricing adjustment arising from such recharacterization.
