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ITAT Bangalore

ITAT Bangalore Set Aside Section 80G Denial for Lack of Adequate Opportunity

December 13, 2025 225 Views 0 comment Print

The CIT(Exemption) canceled 80G approval as the trust did not submit audit reports, expenditure proof, and bank statements. The tribunal remitted the case for fresh consideration with opportunity to comply.

ITAT Deletes ESOP Disallowance but Remands TP Comparables Over Functional Mismatch

December 12, 2025 390 Views 0 comment Print

ITAT Bangalore allowed deduction of ₹55.4 crore ESOP expenses under section 37, holding it as employee compensation cost. ESOP costs may be deductible even if cross-charged from parent company.

Section 11 Exemption Cannot Be Denied for Missing Registration Details in ITR

December 12, 2025 456 Views 0 comment Print

ITAT allowed exemption under Section 11, holding that Revenue cannot deny benefits due to clerical omission of registration details. Key takeaway: procedural mistakes should not override substantive law.

ITAT Bangalore Upholds Tax on Waived Trade Liabilities and Unexplained Purchases

December 12, 2025 195 Views 0 comment Print

The Tribunal held that once the assessee’s own ledger reflected a creditor’s write-off, Section 41(1) was automatically triggered. The waiver in books = taxable cessation of liability.

Disallowance Remanded Because U/s 13A Exemption Not Automatic for TDS

December 10, 2025 321 Views 0 comment Print

The Tribunal held that exemption under Section 13A does not automatically relieve the payer from deducting TDS on interest paid to political parties. It found the earlier High Court ruling relied upon by CIT(A) to be distinguishable. The matter was remitted to the AO to test compliance with the first proviso to Section 201.

ITAT Restores Section 80P Deduction for Cooperative Society Interest Income

December 10, 2025 489 Views 0 comment Print

Disallowance of ₹10.2 lakh on bank interest by the AO was reversed by ITAT, relying on favorable Karnataka HC rulings. The Tribunal confirmed that interest on surplus funds deposited in co-operative banks counts as business income eligible for 80P(2)(a)(i) deduction.

CPC Cannot Override High Court Law: ITAT Deletes PF & ESIC Additions

December 10, 2025 495 Views 0 comment Print

ITAT Bangalore held that disallowances under section 36(1)(va) for employee PF/ESIC contributions before AY 2021-22 were unsustainable, as Finance Act 2021 amendments are prospective. The Tribunal directed AO to delete additions, safeguarding assessee from retrospective impact.

ITAT Clarifies: Working Capital Adjustment May Nullify Interest Addition

December 9, 2025 525 Views 0 comment Print

Tribunal holds that working capital impact must be examined by the TPO when comparables are selected by the Department. If adjustment is granted, no separate interest addition is warranted.

Reimbursement of Forex Loss Not Taxable Due to Capital Nature

December 9, 2025 492 Views 0 comment Print

The Tribunal held that reimbursement of foreign exchange loss on external commercial borrowing cannot be taxed under section 28(iv) as it is capital in nature, avoiding double taxation.

AO Cannot Blow Hot & Cold—TDR Allowed; Penalty Deleted; Interest Disallowance Gone

December 9, 2025 507 Views 0 comment Print

The ITAT held that the AO could not deny TDR cost in both AY 2018–19 and AY 2020–21, directing allowance of the deduction. Authorities cannot blow hot and cold on the same issue across years.

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