Tag Archives: IN THE ITAT CHENNAI BENCH

Retrospective Application of Enhanced Exemption Limit of Rs. 25 Lakhs Under Section 10(10AA)(ii) Allowed for Leave Encashment

By | August 28, 2026
0 Comment

Retrospective Application of Enhanced Exemption Limit of Rs. 25 Lakhs Under Section 10(10AA)(ii) Allowed for Leave Encashment Retrospective Application of Enhanced Exemption Limit of Rs. 25 Lakhs Under Section 10(10AA)(ii) Allowed for Leave Encashment Issue Whether the enhanced leave encashment exemption limit of Rs. 25,00,000 introduced via CBDT Notification No. 31/2023 applies retrospectively to Assessment… Read More »

Disallowance of depreciation on opening WDV of goodwill and vendor compliance expenses deleted in assessee’s favour.

By | August 27, 2026
0 Comment

Disallowance of depreciation on opening WDV of goodwill and vendor compliance expenses deleted in assessee’s favour. Issue Whether the Assessing Officer was justified in re-examining and disallowing depreciation on the opening WDV of goodwill by treating its actual cost as nil, despite the issue being settled in the year of amalgamation. Whether the disallowance of… Read More »

Addition Under Section 69 Unproductive When Immovable Property Purchases Are Recorded in Books

By | August 15, 2026
0 Comment

Addition Under Section 69 Unproductive When Immovable Property Purchases Are Recorded in Books Issue Whether an addition under Section 69 for unexplained investments can be made in the hands of a partnership firm when the acquisition of immovable properties is fully recorded in the firm’s books of account and funded through partners’ capital contributions. Facts… Read More »

Reversal of Bad Debt Provision and Overdue NPA Interest Held Non-Taxable, Rule 6ABA Remanded for Re-examination

By | August 14, 2026
0 Comment

Reversal of Bad Debt Provision and Overdue NPA Interest Held Non-Taxable, Rule 6ABA Remanded for Re-examination Issue Whether the release/reversal of an NPA provision transferred to the Profit & Loss account can be taxed under Section 41(1) as a remission or cessation of trading liability. Whether deduction under Section 36(1)(viia) read with Rule 6ABA is… Read More »

Stamp Duty Value on Date of Agreement Applies Under Proviso to Section 50C for Unregistered Agreements

By | August 13, 2026
0 Comment

Stamp Duty Value on Date of Agreement Applies Under Proviso to Section 50C for Unregistered Agreements Stamp Duty Value on Date of Agreement Applies Under Proviso to Section 50C for Unregistered Agreements Issues Applicability of Stamp Duty Value on Date of Agreement: Whether the proviso to Section 50C requires an agreement to sell to be… Read More »

Ad Ad Hoc Disallowance of Purchases and Business Expenses Is Unsustainable Without Independent Verification or Defect in Books

By | August 11, 2026
0 Comment

Ad Ad Hoc Disallowance of Purchases and Business Expenses Is Unsustainable Without Independent Verification or Defect in Books Issue Whether the Assessing Officer is justified in making an ad hoc disallowance of 50% of purchases under Section 69C and ad hoc disallowances of labor/salary and business expenses under Section 37(1), without conducting independent inquiries, issuing… Read More »

Additions under Sections 69A and 56(2)(x) are unsustainable when consideration is adjusted against prior mortgage liabilities, guideline values are disputed without independent evidence, and cash deposit explanations are rejected without objective verification.

By | August 6, 2026
0 Comment

Additions under Sections 69A and 56(2)(x) are unsustainable when consideration is adjusted against prior mortgage liabilities, guideline values are disputed without independent evidence, and cash deposit explanations are rejected without objective verification. Additions under Sections 69A and 56(2)(x) are unsustainable when consideration is adjusted against prior mortgage liabilities, guideline values are disputed without independent evidence,… Read More »

Foreign exchange fluctuation loss on capital-purpose ECB restatement is capital in nature and non-deductible.

By | August 6, 2026
0 Comment

Foreign exchange fluctuation loss on capital-purpose ECB restatement is capital in nature and non-deductible. Issue Whether foreign exchange fluctuation loss arising on the year-end restatement of an External Commercial Borrowing (ECB) utilized for capital purposes is deductible as revenue business expenditure under section 37(1). Facts The assessee-company availed an External Commercial Borrowing (ECB) from its… Read More »

Interest under section 40 of Black Money Act is unsustainable where foreign source was disclosed and tax statutory exemptions apply.

By | August 6, 2026
0 Comment

Interest under section 40 of Black Money Act is unsustainable where foreign source was disclosed and tax statutory exemptions apply. Issue Whether interest under section 40(1) can be levied when a foreign source is disclosed in the return filed under section 139(1) and the dispute relates only to the quantum of income. Whether interest under… Read More »

Section 40(a)(i) Disallowance Upheld On MFN Withdrawal, Goodwill Depreciation, POS Charges, Software Depreciation, Section 80JJAA Allowed

By | August 6, 2026
0 Comment

Section 40(a)(i) Disallowance Upheld On MFN Withdrawal, Goodwill Depreciation, POS Charges, Software Depreciation, Section 80JJAA Allowed Section 40(a)(i) Disallowance Upheld On MFN Withdrawal, Goodwill Depreciation, POS Charges, Software Depreciation, Section 80JJAA Allowed Issue Whether the disallowance under Section 40(a)(i) for export commission, depreciation on goodwill and software, revenue deduction for land development and Principal Only… Read More »