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ITAT Ahmedabad

Contingent Sale Consideration & Escrow Arrangement – ITAT Ahmedabad Remands Asessee’s Claim of Deduction u/s 54B

September 3, 2025 243 Views 0 comment Print

The ITAT Ahmedabad has remanded a case to the AO to re-examine a taxpayer’s claim for a Section 54B deduction on capital gains from a contingent sale, noting that a critical escrow arrangement was not considered.

Current account transactions & commercial advances are outside Section 2(22)(e) purview

September 3, 2025 636 Views 0 comment Print

The ITAT Ahmedabad bench ruled that loans from current accounts for business purposes cannot be classified as deemed dividends under Section 2(22)(e) of the Income Tax Act. Learn why this decision matters for inter-company financial transactions.

ITAT Upholds Deletion of Section 68 ₹1.5 Cr Unexplained Cash Credit addition

September 1, 2025 456 Views 0 comment Print

ITAT Ahmedabad dismisses a revenue appeal, upholding the deletion of a ₹1.5 crore addition. The tribunal ruled the amount was a loan given, not a cash credit received.

Sale via POA Doesn’t Trigger Capital Gains: ITAT Ahmedabad

September 1, 2025 855 Views 0 comment Print

ITAT Ahmedabad rules that capital gains are taxable only upon the execution of a registered sale deed, not a POA, and an AO’s addition in the wrong AY is invalid.

Failure to provide PAN alone couldn’t be the sole reason to treat sales as unexplained money, when Aadhaar details were submitted

September 1, 2025 396 Views 0 comment Print

Assessee had recorded the cash deposits as sales in the audited books of account, and no discrepancies were found by AO or CIT(A). Failure to provide PAN alone could not be the sole reason to treat the sales as unexplained money, particularly when Aadhaar details were submitted.

ITAT Grants Major Relief to Nirma Ltd. on Subsidy, 80IA Claim & Goodwill Depreciation

September 1, 2025 396 Views 0 comment Print

ITAT Ahmedabad provides tax relief to Nirma Ltd., holding sales tax subsidy as a capital receipt, allowing 80IA deduction and depreciation on goodwill.

Belated Return No Bar: ITAT Allows Unabsorbed Depreciation Carry Forward

September 1, 2025 1458 Views 0 comment Print

ITAT Ahmedabad confirms that a belated return does not prevent the carry-forward of unabsorbed depreciation under Section 32(2), a rule distinct from carry-forward of business losses.

PCIT Cannot Revise Assessment U/s 263 for Different View on Agricultural Income

September 1, 2025 369 Views 0 comment Print

The ITAT ruled that the PCIT’s revision order was invalid as the AO had already examined the assessee’s agricultural income claim, thus not acting erroneously.

PCIT cannot go beyond Limited Scrutiny – Revision u/s 263 Quashed

September 1, 2025 723 Views 0 comment Print

The ITAT Ahmedabad has ruled that the PCIT cannot initiate a revision to an assessment order based on issues that fall outside the scope of a limited scrutiny.

Appeal Cannot Be Dismissed for Non-Payment of Advance Tax on on disputed additions

September 1, 2025 684 Views 0 comment Print

ITAT Ahmedabad ruled that advance tax is only payable on undisputed income, not on disputed additions. A lack of advance tax payment cannot be a precondition for an appeal.

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