The ITAT addressed whether a ₹ 28.94 Cr penalty was time-barred, focusing on whether the penalty initiation date starts with the AO’s satisfaction or the Addl. CIT’s notice.
Dismissing the AO’s view that interest should be restricted to months of operation, Tribunal allowed full claim, reaffirming that partner interest accrues on financial year-end.
Chennai ITAT remanded an ex parte assessment back to the CIT(A) after the assessee filed an affidavit promising full cooperation and no adjournments. The appeal was allowed for statistical purposes.
The ITAT Chennai restored a trust’s appeal to the AO to verify if the asset’s cost was allowed as application of income before disallowing depreciation under Section 11(6) of the Income Tax Act.
The Tribunal directed the CIT(E) to grant Section 12A registration, holding that the Commissioner exceeded jurisdiction by focusing on commercial aspects like fee levels and profitability at the registration stage. The ruling confirms that only the genuineness of the objects and activities must be examined when processing a charitable trust’s application.
Citing lack of sufficient cause for condonation, the Tribunal ruled that even charitable entities cannot escape limitation rules, dismissing the appeal filed after over six years.*
ITAT Chennai found it impermissible for the Department to levy a S 271B penalty after accepting the assessee’s income as commission business in the scrutiny assessment. The key takeaway is that the Department cannot take a divergent stand on the nature of receipts (commission vs. turnover) in penalty proceedings.
ITAT Chennai allowed AM International Holdings’ claim for ₹60.94 lakh software expenses, ruling that the reimbursement paid to a group company, Tamil Nadu Petroproducts Ltd., for terminating an unsatisfactory IT contract was a legitimate business expenditure under Section 37(1) of the Income Tax Act, 1961.
Jewellers and Diamond Traders Association Vs CIT (Exemptions) (ITAT Chennai) The Jewellers and Diamond Traders Association (“the Association”) filed an appeal before the Income Tax Appellate Tribunal (ITAT), Chennai, challenging the rejection of its application for registration as a charitable trust under Section 12AB of the Income Tax Act, 1961 (“the Act”). The application had […]
The Income Tax Appellate Tribunal (ITAT) Chennai ruled in the case of Late Ramasamy Pongianna Gounder Desamani Vs ITO that a loan from one company to another, where a common shareholder holds less than 20% of the voting power in the borrowing company, cannot be taxed as deemed dividend under Section 2(22)(e) of the Income-tax Act, 1961.
