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ITAT Bangalore

Delay of 85 days condoned on medical grounds: ITAT Bangalore

December 19, 2024 438 Views 0 comment Print

ITAT Bangalore held that delay of 85 days in filing of appeal before CIT(A) condoned on medical grounds. Accordingly, matter remitted back to CIT(A) for fresh consideration on merits.

Matter remitted as lower authorities failed to examine evidences with regard to deduction u/s. 80P(2)(a)(i)

December 18, 2024 600 Views 0 comment Print

The assessee is a souharda cooperative society duly registered under the Karnataka Souharda Sahakari Act, 1997 and is engaged mainly in the business of accepting deposits from members and lending credit facilities to its member.

Delay of 1809 days condoned on reasonable cause shown: ITAT Bangalore

December 17, 2024 531 Views 0 comment Print

ITAT Bangalore held that delay of 1809 days in filing of an appeal condoned since reasonable cause shown for the delay. Accordingly, appeal allowed and AO directed to allow Foreign Tax Credit after due verification of Form 67.

No addition of Rs.10 Crore u/s 271(1)(C) without specification of concealment or inaccurate particulars in SCN

December 16, 2024 474 Views 0 comment Print

Addition of Rs.10 Crore under Section 271(1)(c) was not justified as Revenue failed to specify whether the addition was being made alleging concealment of income or for furnishing inaccurate particulars of income.

Addition u/s. 28(iv) towards import of assets free of cost not justified since no benefit derived

December 16, 2024 369 Views 0 comment Print

The assessee is a wholly owned subsidiary of Samsung Electronics Company Ltd. The assessee filed the return of income for AY 2015-16 on 30.11.2015 declaring a total income of Rs. 238,85,10,090/-.

Matter remitted as voluminous documents submitted during hearing before ITAT

December 16, 2024 357 Views 0 comment Print

ITAT Bangalore held that since assessee filed voluminous documents in paperbooks during the course of hearing before ITAT, the matter is remitted back to CIT(A) for consideration of documents furnished by the assessee and fresh decision as per law.

Imposition of penalty u/s. 271(1)(c) for highly debatable issue not justified: ITAT Bangalore

December 10, 2024 432 Views 0 comment Print

Assessee is a credit cooperative society engaged in the business of providing credit facilities to its members for A.Y. 2014 – 15, filed its return of income after claiming deduction u/s. 80 P (2) (a) of the income tax act.

Margin accepted at ALP hence no separate benchmarking of royalty payment required

December 7, 2024 186 Views 0 comment Print

ITAT Bangalore held that no separate benchmarking of royalty payment required when the margin is accepted to be at arms length price (ALP) by the TPO. Thus, appeal of the revenue dismissed.

No Section 271B Penalty for Technical Breach Without Malafide Intent

December 7, 2024 780 Views 0 comment Print

ITAT Bangalore rules penalty under Section 271B cannot be levied for technical breach without malafide intention, in the case of Chinnayellappa Chandrashekar.

Interest received from co-operative society/bank is deductible u/s. 80P(2)(d): ITAT Bangalore

December 5, 2024 417 Views 0 comment Print

ITAT Bangalore held that interest income received from co-operative society or co-operative banks is eligible for deduction under section 80P(2)(d) of the Income Tax Act. Accordingly, matter restored to AO to examine the source of interest income.

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