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Section 263 cannot override AO’s reasoned decision allowing CSR-linked 80G deduction: Mumbai ITAT

July 1, 2025 1179 Views 0 comment Print

Mumbai ITAT rules Section 263 cannot override AO’s reasoned decision allowing 80G deduction on CSR expenses, citing consistent tribunal judgments.

Filing of Form 10BB is directory, not mandatory for Section 11 exemption: ITAT Hyderabad

July 1, 2025 897 Views 0 comment Print

Hyderabad ITAT rules Ramalingeswara Swamy Temple’s Section 11 exemption cannot be denied for delayed Form 10BB filing if submitted before assessment order.

Notice Issued by non-Jurisdictional AO to NRI is invalid: Mumbai ITAT quashes Reassessment

July 1, 2025 1545 Views 0 comment Print

Mumbai ITAT ruled in Sanand Sankardas Vs ITO that reassessment proceedings initiated by a non-jurisdictional Assessing Officer against an NRI are invalid. The tribunal quashed the assessment order, emphasizing that only the International Taxation AO has jurisdiction over NRI cases, rendering notices issued by other AOs void.

ITAT Delhi Deletes ₹2 Cr Cash Credit & ₹1.55 Cr Expenditure Due to Lack of Evidence

June 30, 2025 570 Views 0 comment Print

The ITAT Delhi has deleted ₹2 Crore unexplained cash credit and ₹1.55 Crore unexplained expenditure against Shagun Jewellers, citing insufficient evidence.

ITAT dismisses Appeal Due to Non-Representation; Assessee May Seek Restoration Per Rule 24

June 30, 2025 720 Views 0 comment Print

ITAT Delhi confirms the reassessment of Ram Dev Rice Pvt. Ltd. for AY 2006-07, upholding the addition of Rs. 90 lakh under Section 68 for bogus share capital based on new tangible information.

AO Cannot Base Section 68 Additions on Inferences from Sample Transactions

June 30, 2025 612 Views 0 comment Print

The ITAT Chandigarh addressed the appeal concerning additions made to the income of Lekh Raj Educational & Charitable Trust, involving unexplained corpus funds and unsecured loans.

Section 68 Addition Unsustainable as AO Relied Solely on Third-Party Statement Without Inquiry

June 30, 2025 1179 Views 0 comment Print

ITAT Mumbai overturned an income addition for Leena Haresh Harde, ruling that unsecured loans were genuine, and an assessment based solely on uncorroborated third-party statements without cross-examination is invalid.

Section 148 Notice Invalid Without Section 151(2) Sanction from prescribed authority

June 30, 2025 822 Views 0 comment Print

Mumbai ITAT rules on ITO vs. Nikhil Vinod Aggarwal, invalidating assessment reopening without proper sanction and deleting “on-money” addition due to lack of evidence.

Chit Fund Bad Debts Allowable as Deduction Under Sections 36, 28 & 37

June 30, 2025 780 Views 0 comment Print

 The Madras High Court addressed the tax treatment of royalty payments for brand use and the allowability of bad debts for Shriram Chits Tamilnadu Pvt. Ltd., affirming prior rulings.

Software License Fees Without Enduring Benefits is Revenue Expenditure

June 30, 2025 717 Views 0 comment Print

The Madras High Court upheld that software expenses, including license fees, for Danfoss Industries Pvt. Ltd. are revenue expenditures, not capital, citing no enduring benefit.

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