Interest on FDRs disallowed u/s 80P as investment income exceeded income from credit facilities Issue Whether the interest income of Rs. 1,50,19,858 earned by the assessee (a co-operative agricultural service society) from Fixed Deposits (FDRs) with scheduled banks is eligible for deduction under Section 80P(2)(a)(i) as income “attributable to” the business of providing credit… Read More »
Disallowance under Section 14A read with Rule 8D upheld due to insufficient voluntary disallowance Issue Whether the Assessing Officer was justified in invoking Section 14A read with Rule 8D(2)(ii) to disallow Rs. 1,02,44,219 against exempt income of Rs. 22.42 Crore, rejecting the assessee’s claim that only Rs. 5,774 was incurred to earn such income.… Read More »
Registration application restored to CIT(E) after condoning delay attributed to counsel’s negligence Issue Whether the delay of 424 days in filing the appeal against the rejection of Section 12A registration should be condoned, and if the matter requires fresh adjudication by the CIT(E). Facts Application for Registration: The assessee filed an application seeking registration… Read More »
Assessee not liable for TDS on alleged cash payments absent corroborative evidence or reassessment proceedings Issue Whether the assessee can be treated as an “assessee in default” under Section 201(1)/201(1A) for failing to deduct tax at source (TDS) under Section 194-IA on an alleged cash consideration paid for the purchase of immovable property, where… Read More »
Assessee granted opportunity to seek condonation for late filing to claim Section 80P deduction Issue Whether the assessee, a co-operative agricultural society, is eligible to claim a deduction of Rs. 13,62,092 under Section 80P(2)(a)(i) for Assessment Year 2019-20, despite filing the return of income after the due date prescribed under Section 139(1), in light of… Read More »
Tribunal remands matter to CIT(A) to allow assessee to seek delay condonation for Section 80P claim Issue Whether the assessee, a co-operative agricultural society, is entitled to deduction u/s 80P(2)(a)(i) despite not filing the return of income within the due date specified u/s 139(1), as mandated by Section 80AC. Facts Assessment Year: 2019-20. Original… Read More »
Tribunal remands cash deposit case to CIT(A) for fresh adjudication barring limitation objection Issue Whether the CIT(A) was justified in dismissing the appeal ex-parte on grounds of delay and non-compliance regarding an addition of Rs. 31.85 Lacs for cash deposits. Facts Assessment Details: The appeal pertains to Assessment Year 2011-12. The assessment was framed… Read More »
ITAT remands exemption denial to CIT(A) to consider revised Form 10BB and delay condonation Issue AY 2023-24: Whether CPC was justified in restricting exemption u/s 11/12 due to an inadvertent reporting error in Form 10BB regarding application of funds from earlier years. AY 2024-25: Whether exemption u/s 11/12 can be denied for non-filing of Form… Read More »
Interest on enhanced land compensation is taxable u/s 56(2)(viii) subject to 50% deduction u/s 57 Issue Whether interest received on enhanced compensation u/s 28 of the Land Acquisition Act is exempt from tax or taxable as ‘Income from Other Sources’ u/s 56(2)(viii). Whether the intimation order passed u/s 143(1) by CPC Bangalore was valid.… Read More »
77 Cr Cash Deposit Addition Remanded; Illness & Tech Challenges Valid Causes for Non-Appearance Issue Whether an ex-parte assessment treating cash deposits of Rs. 1.77 Crores as unexplained money under Section 69A is valid when the assessee (a rustic villager suffering from kidney ailments) could not participate in the online proceedings due to illness… Read More »