Bangalore ITAT held that interest earned on statutory SLR and fluid resource deposits maintained under the Karnataka Co-operative Societies Act qualifies for deduction under Section 80P(2)(a)(i).
The ITAT Bangalore condoned a 28-day delay in filing appeal after accepting the assessee’s explanation regarding non-noticing of electronically communicated appellate order. The Tribunal adopted a justice-oriented approach.
ITAT Bangalore held that NIL taxable income disclosed by an Alternative Investment Fund does not automatically negate its creditworthiness. The Tribunal recognized the statutory pass-through taxation mechanism applicable to AIF structures.
ITAT Bangalore held that Section 45(5A) applies prospectively and cannot govern JDAs executed before 01.04.2018. Capital gains from older development agreements must be taxed under the law applicable in the year of transfer.
The Bangalore ITAT held that revision proceedings under Section 264 are intended to provide relief to taxpayers and cannot worsen their position. The Tribunal struck down an enhanced addition made after remand proceedings during demonetisation cash deposit verification.
The Bangalore ITAT held that the Assessing Officer cannot estimate additional profit merely due to a fall in net profit ratio when books of account are not rejected. The Tribunal ruled that suspicion over self-made vouchers without concrete evidence cannot justify arbitrary additions.
The Bangalore ITAT held that once a notice under Section 143(2) initiates regular scrutiny assessment, the Department cannot subsequently resort to summary processing under Section 143(1). The Tribunal quashed massive GST-related adjustments as being without jurisdiction.
The Tribunal held that deducting TDS only on part of the purchase price of immovable property was contrary to Section 194IA. TDS was required to be deducted on the full consideration of ₹4.81 crore.
ITAT holds TDS applies on year-end provisions where payee, amount, and nature are identifiable—assessee treated in default u/s 201. Relief allowed if payees paid tax; no TDS default on salary provisions as deduction arises on payment.
ITAT allows Section 80P deduction to Souharda society, holding registration under Souharda Act qualifies as co-operative society; rejects technical denial, finds no non-member dealings, and rules even disallowances boosting income remain eligible for 80P deduction.
