Income Tax Appellate Tribunal Case Commentaries

Limits on Disallowance under Section 40(a)(ia) and Section 14A: Insights from RNS Infrastructure Ltd. v. Deputy Commissioner of Income Tax

Date: Sep 9, 2021

Limits on Disallowance under Section 40(a)(ia) and Section 14A: Insights from RNS Infrastructure Ltd. v. Deputy Commissioner of Income Tax Introduction RNS Infrastructure Ltd. v. Deputy Commissioner...

ITA Bangalore Refines Eligibility Criteria for Section 80P Deductions in Cooperative Societies Dealing with Nominal and Associate Members

Date: Sep 1, 2021

ITA Bangalore Refines Eligibility Criteria for Section 80P Deductions in Cooperative Societies Dealing with Nominal and Associate Members Introduction The case of M/s. Ravindra Multipurpose...

Exclusion of Amortization of Goodwill as Non-Recurring Expense in TNMM Calculations: Insights from DHR Holding India Pvt. Ltd. v. Joint Commissioner Of Income Tax

Date: Aug 28, 2021

Exclusion of Amortization of Goodwill as Non-Recurring Expense in TNMM Calculations: Insights from DHR Holding India Pvt. Ltd. v. Joint Commissioner Of Income Tax 1. Introduction The case of DHR...

ITAAT Clarifies TDS Reconciliation and Upholds Timely PF & ESI Contributions Deductions

Date: Aug 28, 2021

ITAAT Clarifies TDS Reconciliation and Upholds Timely PF & ESI Contributions Deductions Introduction The case of Indian Geotechnical Services, New Delhi v. Assistant Commissioner Of Income Tax,...

Clarifying Ownership and Incriminating Nature of Documents Under Section 153C: Insights from Cit v. Vision Town Planners (P) Ltd.

Date: Aug 14, 2021

Clarifying Ownership and Incriminating Nature of Documents Under Section 153C: Insights from Cit v. Vision Town Planners (P) Ltd. Introduction The case of Cit v. Vision Town Planners (P) Ltd....

ITA Decision Reinforces Transparency in Share Application Transactions

Date: Aug 14, 2021

ITA Decision Reinforces Transparency in Share Application Transactions Introduction In the appellate decision dated August 13, 2021, the Income Tax Appellate Tribunal (ITA) Bench 'B' of Mumbai...

Estimation of Unaccounted Commission Income from Benami Operations: ITAT Case BHANWARLAL M. JAIN v. DCIT

Date: Aug 7, 2021

Estimation of Unaccounted Commission Income from Benami Operations: ITAT Case BHANWARLAL M. JAIN v. DCIT Introduction The case of BHANWARLAL M. JAIN v. DCIT-CC-1(3), Mumbai adjudicated by the Income...

Rosy Blue v DCIT: Establishing LIBOR-Based Transfer Pricing for Interest-Free Loans

Date: Jul 24, 2021

Rosy Blue v DCIT: Establishing LIBOR-Based Transfer Pricing for Interest-Free Loans Introduction The case of Rosy Blue (India) Pvt. Ltd., Mumbai v. DCIT Central Circle-8(3), Mumbai adjudicated by the...

Jurisdictional Validity and Natural Justice in Tax Assessments: Insights from ACIT CC-13 v. Sur Buildcon Pvt. Ltd.

Date: Jul 16, 2021

Jurisdictional Validity and Natural Justice in Tax Assessments: Insights from ACIT CC-13 v. Sur Buildcon Pvt. Ltd. 1. Introduction The case of Assistant Commissioner Of Income Tax Central Circle-13,...

Presumption of Interest-Free Funds Utilization in Related Party Advances: ITAT Pune's Landmark Ruling

Date: Jul 13, 2021

Presumption of Interest-Free Funds Utilization in Related Party Advances: ITAT Pune's Landmark Ruling Introduction The case of Kumar Agro Products Private Limited, Pune vs. Income Tax Officer, Ward -...

No Addition Under Section 43CA for Less Than 10% Difference in Sale Consideration

Date: Jul 3, 2021

No Addition Under Section 43CA for Less Than 10% Difference in Sale Consideration Introduction The case of Stalwart Impex Private Limited, Mumbai v. Income Tax Officer, adjudicated on July 2, 2021,...

Clarifying the Jurisdiction over Dividend Distribution Tax under Section 115-O in Light of India-France DTAA: An ITAT Mumbai Analysis

Date: Jun 24, 2021

Clarifying the Jurisdiction over Dividend Distribution Tax under Section 115-O in Light of India-France DTAA: An ITAT Mumbai Analysis Introduction The case of Deputy Commissioner Of Income Tax Circle...

Admissibility of Statements and Right to Cross-Examination: Sunita Gadde v. CIT

Date: May 14, 2021

Admissibility of Statements and Right to Cross-Examination: Sunita Gadde v. CIT Introduction The case of Sunita Gadde v. Commissioner of Income Tax (CIT) serves as a pivotal reference in the realm of...

Tribunal Sets Precedent on Non-Mechanical Approval Under Section 151 of the Income Tax Act

Date: May 12, 2021

Tribunal Sets Precedent on Non-Mechanical Approval Under Section 151 of the Income Tax Act Introduction The case of Omkam Developers Ltd. v. CIT adjudicated by the Income Tax Appellate Tribunal...

Establishing Genuine Transactions under Section 68: Ancon Chemplast vs. ITO Sets Precedent

Date: May 1, 2021

Establishing Genuine Transactions under Section 68: Ancon Chemplast vs. ITO Sets Precedent Introduction The case of Ancon Chemplast P. Ltd. vs. Income Tax Officer (ITO) adjudicated by the Income Tax...

Clarity on Section 271(1)(c): Mandating Specificity in Penalty Notices - Singh Consultancy Pvt. Ltd. v. CIT

Date: Apr 10, 2021

Clarity on Section 271(1)(c): Mandating Specificity in Penalty Notices Introduction The case of Singh Consultancy Pvt. Ltd. v. CIT adjudicated by the Income Tax Appellate Tribunal (ITAT) on April 9,...

Reinforcing the Nexus Requirement for Additions under Section 153A: Kuber Khadyan Pvt. Ltd. vs. Assistant Commissioner of Income Tax

Date: Mar 27, 2021

Reinforcing the Nexus Requirement for Additions under Section 153A: Kuber Khadyan Pvt. Ltd. vs. Assistant Commissioner of Income Tax 1. Introduction In the landmark case of Assistant Commissioner Of...

Ensuring Adequate Application of Mind in Reassessment Proceedings: Savita Holdings Pvt. Ltd. v. CIT

Date: Mar 20, 2021

Ensuring Adequate Application of Mind in Reassessment Proceedings: Savita Holdings Pvt. Ltd. v. CIT Introduction The case of Savita Holdings Pvt. Ltd. v. Commissioner of Income Tax (Appeals)...

Rigorous Examination of Share Premium and Investments under Section 68: Insights from Cit v. Direct Mercantile Company Pvt. Ltd.

Date: Mar 20, 2021

Rigorous Examination of Share Premium and Investments under Section 68: Insights from Cit v. Direct Mercantile Company Pvt. Ltd. Introduction The case of Cit v. Direct Mercantile Company Pvt. Ltd.,...

ITAT Upholds Section 80P Deductions for Cooperative Societies’ Interest Income from Non-Licensed Cooperative Banks

Date: Feb 4, 2021

ITAT Upholds Section 80P Deductions for Cooperative Societies’ Interest Income from Non-Licensed Cooperative Banks Introduction The case of New Ideal Cooperative Housing Society Limited, Mumbai v....