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Judiciary

Software termination charge reimbursement to group entity for business purposes allowable

October 26, 2025 462 Views 0 comment Print

ITAT Chennai allowed AM International Holdings’ claim for ₹60.94 lakh software expenses, ruling that the reimbursement paid to a group company, Tamil Nadu Petroproducts Ltd., for terminating an unsatisfactory IT contract was a legitimate business expenditure under Section 37(1) of the Income Tax Act, 1961.

Rectification Can’t Rewrite Scrutiny Order: ITAT Quashes 80P Disallowance for Co-op Society

October 26, 2025 969 Views 0 comment Print

Primary Agricultural Credit Co-operative Society Vs ITO (ITAT Bangalore) Rectification Can’t Rewrite Scrutiny Order — ITAT Quashes 80P Disallowance for Co-op Society; ITAT Bangalore sets aside rectification disallowing 80P deduction – delay condoned for co-operative society Assessee, a Primary Agricultural Credit Co-operative Society, filed return for AY 2020-21 declaring NIL income after claiming deduction u/s 80P(2)(a)(i) […]

Karnataka HC Allows Condonation for 67-Year-Old Who Mistakenly Filed Form 68 Manually Instead of Online

October 26, 2025 522 Views 0 comment Print

The Karnataka High Court set aside the PCIT’s rejection of a condonation delay application for late online Form 68 filing. The court adopted a justice-oriented view, directing a fresh, liberal reconsideration, as the taxpayer’s manual compliance was timely and the error was bona fide.

No Double Deduction: ITAT Allows Separate Claims for Bad Debts – Sections 36(1)(vii) & 36(1)(viia)

October 26, 2025 879 Views 0 comment Print

The Mumbai ITAT upheld the deletion of a disallowance for bad debts, confirming that deductions under Sections 36(1)(vii) and 36(1)(viia) are independent. The ruling followed the Supreme Court’s precedent, allowing the entire bad debt written off since no double deduction was claimed.

Faceless Reassessment Quashed: Notices Issued Beyond Section 151A Scope

October 25, 2025 852 Views 0 comment Print

Karnataka High Court quashes all reassessment notices and orders issued under the faceless scheme for being outside the permissible scope of Section 151A of the Income Tax Act. This ruling voids notices due to a lack of statutory jurisdiction, though the Revenue is allowed to seek a revival if the Supreme Court later rules in its favor.

Reassessment Quashed: Karnataka HC Rules AO Exceeded Jurisdiction Under Section 151A

October 25, 2025 930 Views 0 comment Print

The Karnataka High Court allowed the petition, declaring the reassessment order and all related penalty notices for AY 2016-17 invalid because the initial proceedings were initiated without proper jurisdictional approval under Section 151A. The judgment underscores the critical nature of procedural integrity in faceless assessments, reserving the right for the department to reinstate the case based on a future Supreme Court ruling.

Insurance Company Reassessment Quashed: Notices Invalid for Section 151A Breach

October 25, 2025 549 Views 0 comment Print

Karnataka High Court quashed reassessment notices and orders for AY 2019-20, ruling they were issued without proper jurisdiction and violated the framework of Section 151A. This decision voids the proceedings due to a jurisdictional defect, granting the Revenue liberty to revive the case only after the Supreme Court’s final decision.

Section 263 Order Quashed: Adverse Material Not Shared on Alleged Bogus Purchases

October 25, 2025 627 Views 0 comment Print

ITAT Lucknow set aside a PCIT’s revisional order under Section 263, ruling it was void due to a violation of natural justice. The PCIT used external adverse material (alleging shell company purchases) against the assessee without providing a chance for rebuttal or considering evidence already filed, making the order invalid.

Reassessment Quashed: AO Lacked Jurisdiction Under Faceless Regime Section 151A

October 25, 2025 867 Views 0 comment Print

Karnataka High Court set aside reassessment proceedings for AY 2020-21, ruling the jurisdictional Assessing Officer acted beyond the scope of Section 151A (Faceless Assessment). The decision reinforces that reassessment notices must strictly follow the procedural mandate of the faceless regime, though the Revenue retains the liberty to revive the case if the Supreme Court validates the procedure.

Tribunal Rejects 15-Year-Old PMLA Appeals Over Unexplained Delay

October 25, 2025 516 Views 0 comment Print

Appellate Tribunal under SAFEMA dismissed PMLA appeals filed after 5270 days, ruling that excessive delay and lack of vigilance by the appellants made the appeals legally untenable.

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