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ITAT Hyderabad

Section 14A not apply when there is no dividend income: ITAT Hyderabad

March 28, 2025 999 Views 0 comment Print

ITAT Hyderabad held that disallowance under section 14A of the Income Tax Act is rightly deleted by CIT(A) since assessee has not earned any dividend income. Thus, when there is no dividend income, the provisions of section 14A are not applicable.

Interest on Late TDS Payment Not Deductible; No Addition Without Incriminating Material: ITAT Hyderabad

March 17, 2025 864 Views 0 comment Print

Interest paid on late payment of TDS was not an expenditure wholly and exclusively incurred for the purpose of business and further it was a payment, which was in the form of tax, so it was not an allowable expenditure.

Contrived losses by using Client Code Modification not proved, loss disallowance deleted

March 15, 2025 1188 Views 0 comment Print

ITAT Hyderabad held that no records brought suggesting that assessee has contrived losses by using Client Code Modification. Thus, disallowance of losses only on presumption is not justifiable. Accordingly, disallowance deleted.

MMR not automatically include a surcharge unless highest income slab requirement is met

March 13, 2025 1347 Views 0 comment Print

ITAT Hyderabad rules on Shriram Trust’s surcharge dispute, stating that surcharge applies only if income exceeds ₹50 lakh. Read case details and key findings.

Addition Based on Statements Without Concrete Evidence Not Sustainable

March 7, 2025 747 Views 0 comment Print

ITAT Hyderabad held that determination of sale consideration on the basis of some statements without bringing any concrete material in support of his claim, is not correct. Accordingly, addition is liable to be deleted and appeal filed by revenue dismissed.

Addition u/s. 2(22)(e) untenable as trade advances cannot be characterized as loans or advance

March 6, 2025 702 Views 0 comment Print

ITAT Hyderabad held that trade advances, in the nature of commercial transactions, cannot be characterized as ‘loans or advance’ constituting deemed dividend within the meaning of section 2(22)(e). Thus, addition towards deemed dividend untenable.

Addition for capital contribution from partners not sustained as identity of partners and genuineness of transaction established

March 6, 2025 834 Views 0 comment Print

M/s. GRR Holdings is a firm was incorporated on 31.01.2014 with two partners Shri Gaddam Shyam Prasad Reddy & Shri Syed Fayaz Mohammed. The main objective of the partnership firm is to carry on real estate business.

Resorting to estimation of profit without rejection of books not justified: ITAT Hyderabad

February 27, 2025 762 Views 0 comment Print

ITAT Hyderabad held that resorting to estimation of profit in case of best judgement assessment without rejection of books of accounts is unjustifiable. Accordingly, matter set aside to the file of the lower authorities for reconsideration of the issue.

ITAT Hyderabad Dismisses Appeal Over 10-Year Delay without sufficient cause

February 27, 2025 519 Views 0 comment Print

ITAT Hyderabad rejects Papaiah Pulipati’s appeal due to an inordinate 10+ year delay, citing lack of justification and Supreme Court precedent on condonation of delay.

ITAT Hyderabad Allows ₹1.29 Cr Foreign Tax Credit Despite Late Form 67 Submission

February 23, 2025 1140 Views 0 comment Print

ITAT Hyderabad rules in favor of Baburao Atluri, allowing Foreign Tax Credit despite Form 67 delay. Tribunal cites DTAA precedence over procedural rules.

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