ITAT Bangalore held that year-end expense provisions can attract TDS under the IT Act. The matter was restored for limited verification to determine liability under Sections 201(1) and 201(1A).
Tribunal held that application software licences with limited duration and no ownership rights are revenue expenditure. It deleted the disallowance and ruled that remand by the Commissioner (Appeals) was unjustified.
ITAT Bangalore held that revisionary power u/s. 263 of the Income Tax Act is not justifiable since AO took plausible view of treating the interest chargeable u/s 28 of the Act being attributable to the business & allowed the deduction claimed u/s 80P(2)(a)(i) of the Act. Accordingly, appeal is allowed.
The ITAT Bangalore held that penalty under Section 270A for alleged underreporting and misreporting of income could not survive once the Karnataka High Court condoned the delay in filing the return and restored the assessee’s eligibility for deduction under Section 80IA.
The ITAT Bangalore held that the entire cost of construction claimed by the assessee while computing capital gains on sale of property could not be outrightly disallowed merely due to lack of complete supporting documents.
The ITAT Bangalore held that reopening of assessment was invalid as it was based on an incorrect assumption that the assessee had claimed bogus long-term capital gains (LTCG) from penny stock transactions.
ITAT Bangalore quashed Sec.263 revision, holding AO had examined Model House and ₹9.68 cr expenses in detail; mere change of opinion cannot justify revision.
ITAT Bangalore quashed reassessment for AY 2017-18, holding notice issued on 12-04-2024 time-barred under first proviso to Sec.149(1), despite prior 148A proceedings.
The ITAT Bangalore held that where incriminating documents relating to an assessee are found during a search conducted on another person, the assessment must be framed under Section 153C and not under Section 143(3).
The ITAT Bangalore held that cash received as part of sale consideration for immovable property does not automatically attract penalty under Section 271D if reasonable cause is established under Section 273B.
