ITAT Ahmedabad held that depreciation on goodwill arising from amalgamation was allowable for assessment years prior to AY 2021-22. The Tribunal ruled that amendments excluding goodwill from depreciable assets operate prospectively.
The Tribunal held that mere disallowance of deduction claimed under Section 80GGC does not automatically amount to misreporting of income. It deleted the penalty as there was no evidence of false particulars or fabricated documents.
The Tribunal held that the enhanced exemption limit of ₹25 lakh under CBDT Notification No. 31/2023 applies to leave encashment claims under Section 10(10AA)(ii). Full exemption of ₹10.15 lakh was allowed to the retired SBI employee.
The Tribunal ruled that a clerical mistake in quoting TAN cannot result in denial of TDS credit when Form 16 and Form 26AS clearly establish tax deduction. The decision emphasizes substance over procedural technicalities.
The Tribunal ruled that mere observations about cash transactions are insufficient to levy penalty under Section 271D. A specific finding establishing contravention of Section 269SS is mandatory before imposing penalty.
The Tribunal held that entries found in third-party ERP software during a search cannot alone justify unexplained investment additions under Section 69. Absence of corroborative evidence led to deletion of the entire addition.
The Tribunal held that reassessment proceedings were invalid where the Assessing Officer ignored the assessees detailed response and documentary evidence. ITAT ruled that such action violated principles of natural justice and reflected non-application of mind.
Ahmedabad ITAT held that the Assessing Officer wrongly treated entire business liabilities and receipts as unexplained income. The addition was drastically reduced to estimated profit at 15% of disputed turnover.
The Tribunal held that once the income disclosed in the return filed under Section 148 was accepted without any addition, there could be no allegation of under-reporting or misreporting. The entire penalty of ₹4.91 lakh was deleted.
The Tribunal ruled that corpus donations cannot be taxed merely because Section 12AA registration was granted subsequently. Once registration existed before processing of return, exemption under Section 11 could not be denied.
