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ITAT Chennai

Foreign Tax Deduction Not Allowed as Business Expense: ITAT Chennai Rejects Zoho’s Claim

February 17, 2025 537 Views 0 comment Print

Zoho Corporation’s attempt to deduct foreign taxes as business expenses under Section 37 of the Income Tax Act was rejected by the ITAT Chennai. The tribunal upheld the disallowance, citing Section 40(a)(ii) and emphasizing the distinction between foreign tax credit under Section 90/91 and business expense deductions. This ruling clarifies the limitations on claiming foreign tax deductions and reinforces the interpretation of relevant tax provisions.

ITAT Directs Reassessment in ₹1.8 Crore Capital Gains & Section 54 exemption denial Case

February 16, 2025 705 Views 0 comment Print

Chennai ITAT directs AO to review e-notices and deductions u/s 54 in ₹1.8 crore capital gains case, giving assessee another chance to present evidence.

Demonetization Cash Deposit Addition Unsustainable on Mere Suspicion: ITAT Chennai

February 15, 2025 315 Views 0 comment Print

ITAT Chennai overturns AO’s Rs.53.02 lakh addition to J.K. Jewel Craft’s income, ruling that suspicion alone cannot justify unexplained investment during demonetization.

Cash sourced out of recorded sales cannot be added again u/s. 69A: ITAT Chennai

February 14, 2025 210 Views 0 comment Print

ITAT Chennai held that when the cash is sourced out of recorded sales, the provisions of section 69A of the Income Tax Act could not be invoked since sales have already been offered to tax and taxing same again u/s. 69A would amount to double taxation.

Reopening under section 147 without tangible material is invalid: ITAT Chennai

February 14, 2025 204 Views 0 comment Print

ITAT Chennai held that material/ information referred by AO in reasons recorded cannot be held to be tangible material hence reopening of assessment under section 147 of the Income Tax Act without tangible material is invalid.

Hypothetical Income Not Taxable Under Mercantile System: ITAT Chennai

February 13, 2025 87 Views 0 comment Print

ITAT Chennai held that although the assessee company was following the mercantile system of accounting, only real income could be brought to tax. Hypothetical income cannot be taxed. Hence, appeal of revenue dismissed.

Source of gift satisfactorily explained: ITAT deleted addition

February 13, 2025 375 Views 0 comment Print

In the matter abovementioned ITAT allowed the appeal of the assessee after deleting the addition made u/s 68 after observing the fact that assessee had filed relevent details during assesssment.

ITAT Chennai Sets Aside addition for Unaccounted Jewellery per CBDT Instruction

February 12, 2025 168 Views 0 comment Print

ITAT Chennai held that addition under section 69 towards unaccounted gold and silver jewellery set aside relying on CBDT instruction no. 1916 dated 11.05.1994. Accordingly, appeal of the assessee allowed.

Section 269SS Not Applicable to Broker Acting as Agent or Facilitator of Payment

February 11, 2025 6051 Views 0 comment Print

ITAT Chennai ruled that brokers facilitating land deals are not liable under Section 269SS as they act on behalf of clients and do not receive payments in their own right.

Section 263 Invocation justified as AO passed order without Necessary inquiries

February 9, 2025 399 Views 0 comment Print

ITAT Chennai dismisses FLsmidth’s appeal, upholding PCIT’s order for reassessment due to lack of verification by AO.

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