Whether interest earned on fixed deposits by a credit co-operative society qualifies for deduction under section 80P(2)(a)(i). Ruling & Takeaway: The Tribunal held that interest from depositing surplus business funds in permitted banks is attributable to the credit business and eligible for deduction.
The Tribunal set aside the disallowance of interest after noting fresh evidence indicating business utilisation of borrowed funds. The matter was remanded for reconsideration with an opportunity to substantiate the claim.
The Tribunal held that a manufacturing company failing the 75% trading turnover filter applied by the TPO cannot be retained as a comparable. Dilution of the filter by the DRP only to accommodate one entity was found impermissible, leading to deletion of the comparable.
The Tribunal held that a penalty cannot survive when the quantum addition has been deleted. Once the foundation fails, penalty under Section 271(1)(c) must also fall.
The Tribunal examined whether a large consultancy payment was allowable when the assessee failed to establish its genuineness and business necessity. It upheld the disallowance, holding that mere claims without credible evidence cannot justify deduction of professional expenses.
The Tribunal set aside an addition made only on documents seized from a builder during search proceedings. The ruling underscores that independent evidence against the assessee is mandatory.
ITAT Pune held that non-examination of issue of depreciation claimed on goodwill justifies invocation of revisionary proceeding under section 263 of the Income Tax Act. Accordingly, order sustained and appeal of assessee dismissed.
The Tribunal held that a deduction cannot be disallowed merely due to delayed filing of Form 10CCB when it was available before processing. Procedural delay does not defeat a valid deduction claim.
The Tribunal held that when interest-free funds exceed exempt-income investments, no interest disallowance under Section 14A can be made. The ruling reinforces the presumption laid down by the Supreme Court.
The issue was denial of regular 80G approval due to an inadvertent filing under an incorrect clause. The Tribunal held that a procedural mistake should not bar substantive adjudication.
