The ITAT Pune held that Section 80-IAC does not require startups to complete three years before claiming the deduction. It directed the Assessing Officer to allow the deduction from the first eligible assessment year.
The Tribunal held that transfer pricing adjustments must be based on international transactions and not entity-level figures. It remanded the matter after finding errors in the computation of the arm’s length price.
The ITAT held that a public charitable trust could not be taxed at the Maximum Marginal Rate under Section 167B. It directed taxation at normal rates and held that no tax was payable as the income was below the basic exemption limit.
The ITAT Pune held that compensation received under an Early Retirement Scheme could not be taxed as profits in lieu of salary under Section 17(3)(i). Following earlier judicial precedents, it directed deletion of the addition.
The ITAT Pune held that a genuine claim for exemption under Section 10(20) cannot be rejected merely because the assessee mistakenly claimed a deduction under a different provision in its return.
The Tribunal ruled that proportionate interest disallowance under Section 36(1)(iii) cannot be sustained when the assessee has adequate reserves and interest-free funds to cover the advances. The Revenue failed to rebut the presumption recognized by higher courts.
The Tribunal held that interest earned from surplus funds deposited with banks qualifies for deduction under Section 80P(2)(a)(i). Prudent deployment of business funds does not alter the nature of the income.
ITAT Pune held that Foreign Tax Credit cannot be denied merely because Form 67 was filed after the prescribed due date. The Tribunal ruled that filing Form 67 is a procedural requirement and cannot override the substantive right to FTC under the DTAA.
ITAT Pune ruled that investments in mutual funds and tax-free bonds should not form part of the investment pool for Rule 8D(2)(ii) calculations. The Assessing Officer was directed to verify the details and recompute the disallowance. Both appeals were partly allowed for statistical purposes.
The ITAT Pune held that the CIT(A)/NFAC cannot dismiss an appeal merely for non-prosecution without adjudicating the issues on merits as mandated under Section 250(6). The matter was remanded for fresh consideration with a direction to pass a reasoned and speaking order after granting one final opportunity to the assessee.
