Income Tax : Smt. Ranjana Kumari/Kalta Vs DCIT/ACIT (Central) (ITAT Chandigarh) The appeals involved three assessees belonging to the Kalta Gro...
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Income Tax : Interest income earned by a foreign bank from foreign currency loans extended to Indian corporates was taxable on a gross basis. S...
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 upheld taxation of IPS and CEV subsidies following the Section 2(24) amendment, while partly allowing the appeal on other iss...
Income Tax : ITAT held that Accounting Standard-19 governs accounting treatment but does not determine tax treatment under the Income-tax Act. ...
Income Tax : The ITAT Mumbai held that Explanation 1 to Section 37(1) could not apply in the absence of any finding by the competent authority ...
The ITAT held that once profit is estimated on unaccounted sales, separate additions for wages and operational expenditure cannot be made again under section 69C. The ruling treated such additions as double taxation of the same income stream.
The Supreme Court held that interest paid on borrowed funds was deductible under Section 36(1)(iii) because the loan was used for business purposes. The Court ruled that commercial expediency and composite business operations justified the deduction claim.
The Andhra Pradesh High Court refused to quash summons issued under Section 131(1A) of the Income Tax Act, holding that allegations of mala fide conduct were unsupported by evidence. The Court ruled that statutory investigation based on a Tax Evasion Petition could not be invalidated on speculative claims.
The Supreme Court held that grants disbursed by a statutory corporation formed part of its core business functions and qualified as deductible revenue expenditure. The ruling clarified that such grants were not mere application of income.
ITAT Chennai held that before the 2016 amendment, DSIR approval under Section 35(2AB) related to the in-house R&D facility and not yearly expenditure quantification. The Tribunal upheld full weighted deduction despite partial approval in Form 3CL.
ITAT Bangalore held that NIL taxable income disclosed by an Alternative Investment Fund does not automatically negate its creditworthiness. The Tribunal recognized the statutory pass-through taxation mechanism applicable to AIF structures.
ITAT Delhi confirmed deletion of addition on alleged diversion of interest-bearing funds, holding that hypothetical or notional income cannot be brought to tax. The ruling relied on the principle that only real income is taxable.
The ITAT observed that interest awarded under Section 28 of the Land Acquisition Act differs from ordinary interest under Section 34 and forms part of enhanced compensation. Therefore, taxation provisions relating to interest income were held inapplicable.
Consistency over technicalities: ITAT Mumbai allowed actuarial pension provision as an ascertained liability, rejected mechanical disallowances, and held CBDT instructions cannot override the Income-tax Act.
Extended period of limitation could not be invoked in the absence of fraud, suppression or wilful misstatement with intent to evade tax and accordingly, set aside the entire demand as time barred.
