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Income Tax : ITAT Delhi held legal services are not FTS under Section 9(1)(vii) and directed partner-wise DTAA examination. FTS addition was de...
Income Tax : ITAT Mumbai deleted a Section 69 addition after finding documentary evidence established joint ownership, source of funds, and ear...
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Income Tax : ITAT Surat held that delayed filing of Form 10B is a procedural lapse and remanded the matter after directing the AO to consider t...
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The Tribunal held that interest earned from co-operative banks qualifies for deduction under Section 80P(2)(d). It clarified that co-operative banks are to be treated as co-operative societies. The ruling resolves disputes on eligibility of such income.
The Tribunal upheld reduced addition as earlier years’ rulings fixed profit element at 0.2%. It stressed that consistent facts require consistent treatment. Key takeaway: uniform approach must be followed across years.
The Tribunal held that additions under Section 153C cannot be sustained when based on unverified third-party statements and documents. It found the evidence lacked credibility and was not corroborated. The ruling highlights strict evidentiary standards in search-based assessments.
The Tribunal held that reopening of assessment is invalid when reasons lack details like transaction nature, parties, and dates. It emphasized that vague information and absence of independent application of mind cannot justify reassessment. The ruling reinforces strict standards for valid reopening under tax law.
ITAT Hyderabad holds that Section 68 cannot apply to opening balances; remands ₹55.53 lakh addition for verification, directing AO to examine prior-year records and delete addition if no fresh credit arose during the year.
ITAT ruled that on-money represents business receipts and not pure income. Only profit portion can be taxed, rejecting full addition. The decision reinforces distinction between receipts and income.
The court examined whether delay in Form 10B filing could be condoned but found the authority rejected it on unrelated grounds. It held that such rejection beyond the scope of Section 119(2)(b) was invalid and remanded the matter.
The Court held that reassessment cannot be initiated on issues already examined during scrutiny assessment. It ruled that reopening based on the same material amounts to a change of opinion and is invalid.
ITAT Chennai set aside the appellate order and remanded issues on protective addition, Section 54F exemption, and TDS credit mismatch for fresh adjudication.
The Tribunal held that loans received from NBFCs cannot be treated as unexplained where identity, creditworthiness, and genuineness are established. Absence of incriminating material led to deletion of additions.