Income Tax : The article explains remedies available after adverse tax orders under scrutiny and reassessment. The key takeaway is that choosin...
Income Tax : The Court clarified that mere pendency of information exchange requests under DTAA cannot justify continuing a Look Out Circular. ...
Income Tax : A surge in Section 143(2) notices was triggered by the June 2025 limitation deadline. This explains why cases were picked and how ...
Income Tax : The Tribunal ruled that penalty under Section 271A cannot be levied merely because books were rejected and income was estimated. S...
Income Tax : The ITAT held that an assessment completed before receiving the DVO report under section 50C(2) is invalid. All additions and disa...
Income Tax : Delhi ITAT allows Sanco Holding, a Norwegian company, to compute income from bareboat charter of seismic vessels under Article 21(...
Income Tax : It has been observed that in many cases an assessee may wish to make a claim which was not made in the return of income filed unde...
Income Tax : We have attached a file in excel format. The file contains the format of various details which normally assessing officer asks As...
Income Tax : Tribunal observed that the Assessing Officer failed to establish any mismatch in stock, sales, or accounting records before making...
Income Tax : ITAT Hyderabad held that constituent members of a JV or Consortium can claim deduction under Section 80IA(4) when they actually ex...
Income Tax : The Tribunal found that full payment, TDS deduction, and transfer of possession established completion of the transaction for capi...
Income Tax : ITAT Rajkot held that cash deposits made during demonetization were fully supported by audited books of account, cash books, and b...
Income Tax : The Hyderabad ITAT held that purchases cannot be treated as bogus merely because the supplier failed to respond to a notice under ...
Income Tax : Instruction No.1/2015 Clarification regarding applicability of section 143(1D) of the Income-tax Act, 1961- Vide Finance Act, 2012...
ITAT Delhi held that trade scheme payment to sales promoters whether pure reimbursement or not needs proper verification and since AO granted relief without proper verification and application of mind, PCIT rightly invoked revisionary proceedings u/s. 263.
The ITAT Bangalore confirmed that an initial order’s failure to consider a binding High Court ruling on bad debt deductibility constitutes a mistake apparent from record. This allowed the bank to claim a deduction under Section 36(1)(vii) for non-rural bad debts via rectification, dismissing the Revenue’s appeal. The key takeaway is that disregarding settled jurisdictional law is a rectifiable error, not a debatable issue.
The ITAT Ahmedabad deleted the Section 36(1)(iii) disallowance of interest expense after the real estate firm successfully proved that the mutual fund investment in question was made using interest-free own funds, not borrowed capital. The ruling emphasizes that disallowance requires evidence of borrowed funds being diverted for non-business purposes.
ITAT Chennai granted relief, holding that reversal of a provision for liquidated damages, which was disallowed and subsequently taxed under VSV Scheme in earlier years, cannot be taxed again under Section 41(1). This prevents double taxation.
ITAT Delhi directed the AO to compute Annual Letting Value (ALV) only for the portion of the house property actually rented out (third/fourth floors). Taxing the entire property based on assumptions, ignoring the owner’s self-occupation, was held to be unjustified.
ITAT Kolkata invalidated the assessment under Section 143(3), ruling that the foundational notice under Section 143(2) was void ab initio for failing to comply with the mandatory CBDT prescribed format. CBDT instructions issued under Section 119 are binding on the department.
ITAT Kolkata deleted a Rs.7.11 crore addition under Section 68, ruling that an assessee’s comprehensive documentary evidence (PAN, bank statements) cannot be dismissed merely because subscribers failed to appear for summons. The onus shifted back to the Revenue.
ITAT Pune reaffirmed that 15% accumulation permitted under Section 11(1)(a) must be computed on gross receipts. Revenue’s argument restricting it to surplus was rejected, relying on consistent rulings of Supreme Court and High Courts.
The High Court set aside the ex-parte assessment and appeal order, granting the partnership firm another opportunity to respond to the Section 148 notice. The ruling accepts the taxpayer’s non-response as due to bona fide, unavoidable circumstances.
Bombay High Court held that delay in filing of Form No. 10 was condoned since activities of trust are genuine and denial of benefit of accumulation u/s. 11(2) due to delay in Form No. 10 would cause genuine hardship.
