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Judiciary

Section 14A Explanation Applies Prospectively from 01/04/2022, Not Retrospectively

March 8, 2025 783 Views 0 comment Print

Explanation to Section 14A has only a prospective effect from April 1, 2022, and cannot be retrospectively applied to earlier assessment years.

ITAT Ahmedabad Dismisses Appeal Due to Assessee’s Non-Appearance

March 8, 2025 426 Views 0 comment Print

ITAT Ahmedabad dismisses Somnath Kelavni Mandal’s income tax appeal due to continuous absence in proceedings. Case pertains to unexplained cash deposits under Section 69A.

Section 43A not invocable when there is only reinstatement of fluctuation loss

March 8, 2025 852 Views 0 comment Print

ITAT Delhi held that provision of section 43A of the Income Tax Act not invocable when there is only reinstatement of fluctuation loss as per accounting standards and there is no actual payment or remittance. Thus, appeal allowed.

ITAT Deletes ₹12 Lakh Addition on Post-Demonetization SBN Deposits

March 8, 2025 885 Views 0 comment Print

ITAT Bangalore reverses addition of ₹12 lakh under Section 68, accepting sales as the source of cash deposits made during demonetization by Raju Rajesh.

2202-Day Delay in Income Tax Appeal Filing Condoned in Palmera Co-op Case

March 8, 2025 840 Views 0 comment Print

ITAT Mumbai condones a 2202-day delay in filing appeal by Palmera Co-op Housing Society. Bona fide belief in rectification under Section 154 upheld.

Indian Subsidiary Not a Dependent Agency PE if Transactions Are Subject to TPO Adjustment

March 8, 2025 642 Views 0 comment Print

ITAT Bangalore sets aside AO’s decision in Qlik Tech International AB vs DCIT, addressing PE classification, TDS credit, and tax refund interest disputes.

Section 69A Additions Based on Suspicion Without Evidence Deleted by ITAT

March 8, 2025 963 Views 0 comment Print

ITAT Chennai deletes additions under Section 69A for cash deposits made during demonetization by P. Tamilmani. Case highlights proper accounting and unjustified suspicions.

ITAT Mumbai Sets Aside CIT(A) Order Due to Lack of Proof of Service of Notice

March 8, 2025 666 Views 0 comment Print

ITAT Mumbai sets aside CIT(A) order in Pukhraj Shreemalji vs. ITO due to lack of proof of notice service, restoring the matter for fresh adjudication.

Insurance Company Negative Reserves Not Distributable Surplus & Cannot be taxed

March 8, 2025 738 Views 0 comment Print

ITAT Mumbai dismisses Revenue’s appeal against Kotak Mahindra Life Insurance, citing precedents favoring the insurer on taxation of surplus and negative reserves.

Reconstruction & COVID-19 Disruptions: Bombay HC Condones Form-10B Filing Delay

March 8, 2025 471 Views 0 comment Print

Bombay High Court allows Karnataka Sangha’s appeal, condoning a 15-day delay in filing Form-10B under the Income Tax Act, citing reconstruction and COVID-19 disruptions.

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