The Tribunal held that payment for cement shortage during transport arose from contractual obligation and was compensatory in nature. As no statutory violation was established, deduction under Section 37(1) was allowed.
Arulcheyal Kainkarrya Sabha Vs CIT (Exemptions) (ITAT Chennai) The appeals before the Income Tax Appellate Tribunal (ITAT), Chennai, arose from the order dated 22.09.2025 passed by the Commissioner of Income Tax (Exemptions) [CIT(E)], Chennai, rejecting the assessee trust’s applications for registration under Sections 12AB and 80G of the Income Tax Act, 1961. The assessee is […]
The Tribunal clarified that dismissal of an SLP does not amount to declaration of law under Article 141. It distinguished prior rulings and held that defective penalty notices invalidate the levy.
The Tribunal emphasized 33%–40% value addition at the UTK unit and scientific assembly processes to conclude that real manufacturing took place. It directed deletion of disallowances made across five assessment years.
The ruling highlights that mere failure to file return, without concealment or tax evasion, does not automatically attract Section 270A penalty. Bona fide explanation and TDS compliance protected the taxpayer.
The Tribunal held that once capital gains are correctly taxed in one assessment year, protective addition in another year cannot survive. Deduction under Section 54F was also allowed as conditions of the proviso were not met.
The Tribunal held that where disallowance was accepted and taxes paid during revision under Section 263, penalty under Section 270A was not warranted. The appeal was allowed and penalty deleted.
ITAT Chennai held that disallowance in terms of section 14A of the Income Tax Act read with rule 8D restricted to the extent of investment which yielded exempt income. Accordingly, disallowance restricted and appeal partly allowed.
Penalty was imposed alleging misreporting due to belated PF/ESI remittance. The Tribunal ruled that a disclosed claim later disallowed does not fall under any clause of Section 270A(9), and deleted the penalty.
The Revenue denied deduction by treating bank interest as Income from Other Sources. The ITAT dismissed the appeal, holding that the interest income forms part of business profits eligible for Section 80P.
