Income Tax : The three-judge bench of Supreme Court of India in the case of Deputy Commissioner of Income Tax v. M/S Pepsi Foods Ltd struck dow...
Income Tax : A perusal of this order reveals that the Tribunal has recorded a finding that it is empowered by Section 254 of the Act to stay pr...
Income Tax : The existing provisions of Section 254(2) provide for a time-limit of four years from the date of the order of the Appellate Tribu...
Income Tax : Bombay High Court held that failure to pass a fresh assessment within Section 153 limitation required acceptance of the returned i...
Income Tax : ITAT held the assessment time-barred as the AO failed to pass the final order within the mandatory timeline under Section 144C(13)...
Income Tax : Provisions that were typically restricted or viewed as contingent become fully deductible business expenses the moment they were q...
Income Tax : The ITAT held that the assessment was invalid because it was completed by an Assistant Commissioner who lacked pecuniary jurisdict...
Income Tax : ITAT Mumbai allowed deduction of ESOP expenses under Section 37(1) by following Karnataka High Court's ruling in Biocon Ltd. Tribu...
Bombay High Court held that failure to pass a fresh assessment within Section 153 limitation required acceptance of the returned income.
ITAT held the assessment time-barred as the AO failed to pass the final order within the mandatory timeline under Section 144C(13).
Provisions that were typically restricted or viewed as contingent become fully deductible business expenses the moment they were quantified, crystallized, and physically paid out before the tax return filing deadline. Revenue could not arbitrarily disallow a flat percentage of direct operational or employee welfare expenses based on general suspicion.
The ITAT held that the assessment was invalid because it was completed by an Assistant Commissioner who lacked pecuniary jurisdiction under CBDT Instruction No. 1/2011. The assessment order was set aside.
ITAT Mumbai allowed deduction of ESOP expenses under Section 37(1) by following Karnataka High Court’s ruling in Biocon Ltd. Tribunal directed Assessing Officer to allow expenditure for relevant assessment year
The ITAT Hyderabad held that the assessment orders were time-barred under Section 153 despite the DRP process. Both assessments were quashed after applying the limitation prescribed under the Act.
The ITAT Mumbai held that sales tax and similar State Government incentives were capital receipts because the schemes were intended to promote industrialisation, backward area development and employment, applying the Supreme Court’s purpose test.
Tribunal held that the estimated disallowance under Section 14A should be restricted and should not form part of book profits, following the Special Bench decision in Vireet Investments Pvt. Ltd.
The ITAT held that sales tax subsidy granted under industrial incentive schemes constituted a capital receipt because its purpose was industrial development rather than business profits. The Revenue’s appeal was dismissed and the subsidy was excluded from taxable income and book profits.
The ITAT Delhi held that the assessee could not claim deduction under Section 54 for the first time before the Tribunal when it had neither been claimed in the return nor during assessment proceedings. The Tribunal also upheld the remand of the Section 50C issue to the Assessing Officer.
