Income Tax : Budget 2026 proposes allowing taxpayers to file an updated return even after receiving a reassessment notice under Section 148. Wh...
Income Tax : Misreporting under Section 270A(9) applies only to six specific circumstances. Where the assessment order does not clearly establi...
Income Tax : The law now proposes a single consolidated assessment-cum-penalty order for under-reporting of income, reducing multiple proceedin...
Income Tax : Detailed overview of penalties under various sections of the Income Tax Act, covering defaults in tax payment, reporting, document...
Income Tax : Section 270A penalties must specify the exact misreporting clause. Vague notices invalidate penalties and can restore immunity und...
Income Tax : Explore amendments to section 253 of Income-tax Act, adjusting time limits for filing appeals to the Income Tax Appellate Tribunal...
Income Tax : The tribunal examined whether duty drawback should be taxed on accrual or actual receipt. It held that as per law, duty drawback i...
Income Tax : ITAT held that interest earned on bank deposits is taxable and not covered by the principle of mutuality. The ruling confirms that...
Income Tax : The Tribunal restored the penalty matter as the quantum addition was sent back to the AO. It held that penalty must follow the out...
Income Tax : The issue was penalty for misreporting on sale of land classified as capital asset. The Tribunal held the issue was debatable and ...
Income Tax : The case examined whether disallowance under section 94(7) should be limited to exempt dividend. The Tribunal held that the provis...
The Tribunal held that a ₹15.22 crore one-time payment to distributors, necessitated by a business model shift, was a valid revenue expenditure under Section 37, driven by commercial necessity. The ruling affirms that business prudence justifies compensation to maintain continuity without creating a capital asset.
The ITAT deleted penalties under both Sections 271(1)(c) and 270A, ruling that merely making a bona fide but ultimately unsustainable tax claim under the India-UK DTAA does not attract a penalty. The Tribunal held that a difference in legal interpretation, especially in complex international tax issues, does not constitute concealment or misreporting of income.
Upholding the CIT(A)’s decision, the ITAT confirmed that the charitable trusts claim for exemption on ₹2.45 crore application of income could not be denied. The ruling establishes that the registration granted under Section 12AA, even if initially delayed, holds legal force for the current assessment year, nullifying the AOs attempt to tax voluntary contributions.
The ITAT Hyderabad quashed a penalty order imposed under Section 270A, ruling it was barred by limitation under Section 275(1)(c) because the order was passed in December 2021, six months after the statutory deadline of June 30, 2021. The Tribunal held that since the penalty was initiated in December 2020, the outer limit for passing the order had clearly expired.
The ITAT Ahmedabad, applying the Supreme Court’s Rajeev Bansal ruling and Gujarat High Court’s precedent, invalidated a reassessment for AY 2017-18. The order u/s 148A(d) and fresh u/s 148 notice, stemming from a deemed notice issued on 30.06.2021, were held time-barred as they were issued 20 days beyond the maximum seven-day ‘surviving time’ limit.
ITAT Mumbai ruled that the date of a Letter of Intent (LOI), 14.02.2011, constitutes the date of acquisition for a flat, allowing indexation from that date for Long-Term Capital Gains computation.
Ahmedabad ITAT set aside a ₹13.86 lakh penalty u/s 270A after the quantum appeal was restored to the CIT(A) for a fresh decision, citing the consequential nature of penalty.
Delhi ITAT ruled that Pratt & Whitney’s overseas aircraft engine repair is not Fees for Technical Services (FTS) as it fails the DTAA’s “make-available” test. The ₹242 Cr demand was deleted.
ITAT, Pune, ruled in Manisha Dhananjay Holkar vs. ITO that CIT (Appeals) [CIT(A)] cannot dismiss an appeal solely due to appellant’s non-appearance.
Following SC’s E-Funds ruling, Delhi ITAT confirmed Concentrix US has no PE in India. The Tribunal also held that IPLC/link charges are non-taxable reimbursements, not ‘royalty’ under Article 12 of the India-US DTAA.
