Tag Archives: IN THE ITAT DELHI BENCH

Supreme Court COVID Extension Of Limitation Period Is Not Applicable To Departmental Assessment Proceedings

By | June 16, 2026
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Supreme Court COVID Extension Of Limitation Period Is Not Applicable To Departmental Assessment Proceedings Issue Whether the extension of the limitation period granted by the Supreme Court during the COVID-19 pandemic applies to administrative assessment proceedings conducted by the Income Tax Department, and whether the Tribunal’s refusal to apply this extension constitutes a “mistake apparent… Read More »

Hiring Receipts Of Trust Treated As Commercial Business Income Whereas Incidental Expenditures Allowed As Application

By | June 16, 2026
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Hiring Receipts Of Trust Treated As Commercial Business Income Whereas Incidental Expenditures Allowed As Application Hiring Receipts Of Trust Treated As Commercial Business Income Whereas Incidental Expenditures Allowed As Application Issue Whether the receipts earned by a charitable trust from hiring out its conference and auditorium facilities along with other amenities constitute commercial business income… Read More »

An Intimation Under Section 143(1) Does Not Merge Into a Section 143(3) Scrutiny Order, and Adjustments Must Be Appealed Separately

By | June 15, 2026
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An Intimation Under Section 143(1) Does Not Merge Into a Section 143(3) Scrutiny Order, and Adjustments Must Be Appealed Separately Issue Whether adjustments made in an intimation under Section 143(1) merge into a subsequent scrutiny assessment order passed under Section 143(3) (which merely adopted the 143(1) figures without independent modifications), thereby allowing the assessee to… Read More »

Mandatory CSR Expenditures to Registered Trusts Qualify for Section 80G Deductions and Working Capital Adjustments Preclude Separate Interest Imputation on Delayed Receivables

By | June 15, 2026
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Mandatory CSR Expenditures to Registered Trusts Qualify for Section 80G Deductions and Working Capital Adjustments Preclude Separate Interest Imputation on Delayed Receivables Issue Whether an assessee can claim a tax deduction under Section 80G for corporate donations made to a registered, approved trust, even if that expenditure forms part of its mandatory Corporate Social Responsibility… Read More »

Forex Fluctions on Export Proceeds are Operating in Nature and CSR Donations Qualify for Section 80G Deductions

By | June 15, 2026
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Forex Fluctions on Export Proceeds are Operating in Nature and CSR Donations Qualify for Section 80G Deductions Issue Whether foreign exchange gains/losses arising from the realization of normal export proceeds from Associated Enterprises (AEs) should be treated as operating in nature when computing the Profit Level Indicator (PLI) under the Transactional Net Margin Method (TNMM).… Read More »

Donations Sourced From Corporate Social Responsibility Funds Qualification Under Section 80G Are Fully Valid And Omitted Tax Credits Under Section 90 Must Be Factually Restored

By | June 13, 2026
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Donations Sourced From Corporate Social Responsibility Funds Qualification Under Section 80G Are Fully Valid And Omitted Tax Credits Under Section 90 Must Be Factually Restored Donations Sourced From Corporate Social Responsibility Funds Qualification Under Section 80G Are Fully Valid And Omitted Tax Credits Under Section 90 Must Be Factually Restored Issue Whether a company can… Read More »

An Intimation Under Section 143(1) Does Not Merge Into A Scrutiny Assessment Order Passed Under Section 143(3) And Adjustments Therein Must Be Appealed Separately

By | June 13, 2026
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An Intimation Under Section 143(1) Does Not Merge Into A Scrutiny Assessment Order Passed Under Section 143(3) And Adjustments Therein Must Be Appealed Separately Issue Whether an intimation issued under Section 143(1) merges into a subsequent scrutiny assessment order passed under Section 143(3) when the Assessing Officer merely adopts the income from the intimation without… Read More »

Corporate Social Responsibility Spend Is Eligible For Section 80G Deductions And Working Capital Adjustments Preclude Separate Interest Imputations On Outstanding Receivables

By | June 13, 2026
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Corporate Social Responsibility Spend Is Eligible For Section 80G Deductions And Working Capital Adjustments Preclude Separate Interest Imputations On Outstanding Receivables Issue Whether Corporate Social Responsibility (CSR) expenditure, which is statutorily disallowed as a business expense under Section 37(1), can be claimed as a deduction under Section 80G if the donation is made to a… Read More »

Penalty Cannot Be Sustained on Estimated Profit Additions or Unsubstantiated Loose Sheets

By | June 12, 2026
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Penalty Cannot Be Sustained on Estimated Profit Additions or Unsubstantiated Loose Sheets Issue Whether a penalty for concealment of income under Section 271(1)(c) is legally sustainable when the underlying additions are based merely on an estimation of gross profit or on unsubstantiated loose sheets recovered during a tax proceeding. Facts The Additions: For the Assessment… Read More »

Assessment Order Under Black Money Act Quashed as TOLA Extensions Do Not Apply to Overcome Statutory Limitation

By | June 12, 2026
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Assessment Order Under Black Money Act Quashed as TOLA Extensions Do Not Apply to Overcome Statutory Limitation Issue Whether the time-limit extensions provided under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA) apply to the Black Money Act, and whether an assessment order passed beyond the statutory two-year limit… Read More »