Chennai ITAT rules Dividend Distribution Tax (DDT) is a company tax and not covered by DTAA, rejecting the refund claim. Separately, it capped the TDS disallowance at 30% under Section 40(a)(ia).
SCIPL Vs DCIT: ITAT Delhi deletes huge additions, ruling that WhatsApp Excel sheets are dumb documents. Suspicion isnt evidence; corroboration is mandatory in search assessments. Deletions on alleged foreign fund diversion & bogus expenses upheld.
ITAT Ahmedabad held that law doesn’t require brought forward additional depreciation from preceding year to be set off against opening WDV of the assets. Thus, revision u/s. 263 of the Income Tax Act not sustained as order of AO not erroneous.
ITAT Chennai allowed Lotus Footwear’s 100% SEZ deduction u/s 10AA for Unit-2, ruling it was a new undertaking established with fresh capital and not a splitting of the existing unit
The ITAT Delhi remanded the ₹3.94 Cr unexplained cash deposit addition against commission agent Manoj Kumar to the CIT(A). The Tribunal ordered a fresh verification of the taxpayer’s cash flow, noting the lack of agreements and reconciliation of deposits with books.
The ITAT Delhi quashed the reassessment against Lombard Portfolio Pvt. Ltd., ruling the Section 148 notice was time-barred. Following the Supreme Court’s mandate in the Ashish Agarwal case.
ITAT Delhi ruled that salary paid to expatriates on local contracts is deductible and that CSR expenditure disallowed under Section 37(1) remains eligible for deduction under Section 80G.
ITAT Ahmedabad held that loss on foreign currency derivative transactions and loss on account of exchange rate difference are not speculative in nature and hence the same is allowable as business expense. Accordingly, order passed by Pr. CIT u/s. 263 directed to be quashed.
ITAT Delhi held that as per section 144C(13) of the Income Tax Act final assessment order is to be passed within one month from the end of the month in which directions issued by DRP is received by AO. Assessment order passed beyond the period prescribed u/s. 144C(13) is time barred and liable to be quashed.
ITAT Cochin held that disallowance of notional interest u/s. 36(1)(viii) of the Income tax Act set aside since borrowed funds were used for renovation of leasehold premises and the same is allowed as revenue expense and hence interest on such borrowing is allowed as revenue expense.
