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Allowability of use of Extrapolated Data for comparables inspite of having different year-end in ITeS transfer pricing dispute

August 18, 2025 561 Views 0 comment Print

While computing arm’s length price (ALP), it is required both the tested party and the comparable should have similar financial year endings for proper analysis of the functions performed, assets employed and risks assumed.

Limitation for 271D/271E Penalty Runs from AO’s Satisfaction, Not JCIT Notice

August 18, 2025 1764 Views 0 comment Print

The Mumbai Income Tax Appellate Tribunal quashes penalties for being time-barred and invalidates a reassessment notice, clarifying key tax law provisions on limitation and sanctioning authority.

ITAT Cochin Upholds Penalty for Cash Sale of Property Under Section 269SS

August 18, 2025 7221 Views 0 comment Print

The ITAT Cochin bench ruled that receiving cash for property at registration violates Section 269SS, overturning a prior decision.

Charitable trusts can freely use accumulated funds under Section 11(2)

August 18, 2025 1656 Views 0 comment Print

The ITAT Lucknow tribunal clarifies that charitable trusts can utilize accumulated income without first spending their current-year income, as per Section 11(2).

Entry provider can be taxed only on commission, not entire accommodation entries

August 18, 2025 5838 Views 0 comment Print

The ITAT Lucknow tribunal rules that an accommodation entry provider can only be taxed on its commission income, not the entire amount of routed funds, a clarification of Section 68.

No Escape from 271B Penalty if Audit Report Not Signed in Time: ITAT Lucknow

August 18, 2025 1284 Views 0 comment Print

Lucknow ITAT confirms penalty under section 271B, ruling that a taxpayer is responsible for timely tax audit completion and report submission, and blaming the CA is not a valid defense.

Addition of unexplained stock u/s. 69 upheld as claim of stock not supported by verifiable evidences

August 18, 2025 549 Views 0 comment Print

ITAT Surat held that addition of unexplained stock as unexplained investment u/s. 69 of the Income Tax Act upheld due to claim of closing stock was not supported by any verifiable evidences. Accordingly, ground of appellant dismissed.

Application of trust u/s. 12AB rejected as objects are not for benefit of general public

August 18, 2025 681 Views 0 comment Print

ITAT Ahmedabad application for registration of trust under section 12AB of the Income Tax Act since object of the applicant is not working for benefit of general public at large but is working for specific section of society. Accordingly, appeal of assessee dismissed.

Matter of unexplained deposit remanded as assessee failed to represent before AO and CIT(A)

August 18, 2025 453 Views 0 comment Print

The Ld. AR requested that the matter may be remitted to the Ld. AO while the Ld. DR supported the order of the Ld. CIT(A). After considering the facts of the case, we deem it appropriate in the interest of justice and fair play that another opportunity needs to be provided to the assessee to represent her case properly before the Ld.

Foreign Tax Credit cannot be denied merely for delayed filing of Form No. 67: ITAT Jaipur

August 18, 2025 651 Views 0 comment Print

ITAT Jaipur held that delayed filing of Form No. 67 cannot be reason for denial of Foreign Tax Credit since filing of Form 67 is procedural/ directory requirement. Accordingly, appeal allowed and order of CIT(A) set aside.

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