The issue was whether revision under section 263 could be invoked to deny 80P deduction on interest from co-operative bank deposits. The ITAT held that such revision is invalid when the AO has taken a legally settled and permissible view.
Swaroop Kudalkar Vs Assessment Unit (ITAT Pune) Ex-parte Assessment & NFAC Dismissal Set Aside in Legal Heir Case; Matter Remanded for Fresh Adjudication – ITAT Pune The Pune Bench of the ITAT, in Swaroop Kudalkar (Legal Heir of Late Roshan Kudalkar) vs. Assessment Unit (ITA No.2132/PUN/2025, AY 2020-21, order dated 18-12-2025), set aside the ex-parte […]
The tribunal held that interest earned on deposits with Cooperative Banks qualifies for deduction under Section 80P(2)(d), overturning the earlier disallowance.
The Tribunal held that CSR expenditure disallowed as business expense can still qualify for deduction under Section 80G. The key takeaway is that both provisions operate at different stages of computation.
ITAT held that CSR expenditure disallowed under section 37 can still qualify for deduction under section 80G. The ruling clarifies that both provisions operate independently.
The reassessments were initiated after four years based on section 68 but concluded under section 115BBC. The ITAT held that absence of valid jurisdiction and mismatch of sections rendered the reassessments void.
The issue was whether unexplained deposits of ₹94.89 lakh could be sustained when evidence was not produced due to a serious family medical crisis. The ITAT held that genuine hardship warranted a fresh opportunity and remanded the matter for proper verification.
The Tribunal held that restricting TDS credit at the CPC stage is unsustainable when Form 26AS supports the claim. Full credit must be allowed after verification under Section 199 and Rule 37BA, ensuring income–TDS linkage.
The dispute involved confirmation of unexplained cash deposits without granting a requested VC hearing. The Tribunal held that denial of virtual hearing violated natural justice. The matter was remanded for fresh adjudication.
ITAT Pune ruled that interest earned by a cooperative society from ICICI and HDFC banks retains its character as business income and qualifies for deduction under section 80P(2)(a).
