Tag Archives: IN THE ITAT DELHI BENCH

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

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

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

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

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

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

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

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 »

Reassessment Order Quashed as Assessing Officer Deviated from Reasons Recorded for Reopening

By | June 12, 2026

Reassessment Order Quashed as Assessing Officer Deviated from Reasons Recorded for Reopening Issue Whether a reassessment order under Section 147 is legally sustainable if the Assessing Officer (AO) completely deviates from the original reasons recorded for reopening the assessment and makes additions on entirely different grounds. Facts Initiation of Reassessment: For the Assessment Year (AY)… Read More »

Assessing Officer Cannot Make Additions on New Issues Without Assessing the Original Grounds Used for Reopening

By | June 11, 2026

Assessing Officer Cannot Make Additions on New Issues Without Assessing the Original Grounds Used for Reopening Issue Whether the Assessing Officer (AO) exceeds his jurisdiction by making additions under Section 68 regarding share application money received from two entities, when the sole basis and “reason to believe” recorded for reopening the assessment under Section 147… Read More »