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.
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.
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.
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.
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.
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.
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.
Tribunal holds that selling goods below cost does not create marketing intangibles and cannot be capitalised as brand-building expenditure. ESOP reimbursements are reaffirmed as allowable business expenses without TDS.
Incorrect Form 3CD reporting led CPC to treat rental income and capital gains as business income. The Tribunal ruled that such mismatches cannot justify additions without verification.
The Tribunal ruled that interest from co-operative bank deposits is attributable to business activity and eligible for deduction under Section 80P(2)(a)(i). The disallowance of ₹8.98 lakh was ordered to be deleted.
