Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


DCIT v. Kolte Patil Integrated Townships Ltd. (2025) 235 TTJ 113 / (Pune)(Trib)

S. 147: Reassessment-No failure to disclose material facts-Notices issued under S. 148 under the new regime for the relevant asst. yrs. 2014-15 and 2016-17 on 25th July, 2022 and 26th July, 2022, respectively, were barred by limitation-Reassessment proceedings are quashed.[S. 148, 148A(b)]

ACIT v Ludhiana Beverages (P) Ltd. (2025) 235 TTJ 535 (Amritsar)(Trib)

S. 145: Method of accounting-Rejection of books of account-Estimation of gross profit-No comparative cases-GP declared was more than earlier years-Addition was deleted-ERP software expenses as revenue expenditure cannot be accepted-Purchase invoices were produced before the Assessing Officer-No violation of R.46A [S.37 (1), 145(3) 251, R.46A]

Kaizen Enterprises (P) Ltd. v. ACIT (2025) 235 TTJ 295/ 128 ITR 270/ 172 taxmann.com 621 (Jaipur (Trib)

S. 145: Method of accounting-Builder and developer-Project completion method-Advances received by the assessee from the customers cannot be taxed in this year when the same have been adjusted in the sales in the assessment year 2018-19

Subhash Chander Gupta v. ITO (2025) 235 TTJ 883 (Chd)(Trib)

S. 143(2): Assessment-Notice-Physical copy of the notice has not been brought on record-Reassessment is bad in law. [S. 147, 148]

Dhanottam Vasant Lonkar v. ITO (2025) 235 TTJ 265 (Pune)(Trib)

S. 143(2): Assessment-Notice-Notice sent to wrong address-Assessment order was illegal and void ab initio. [S. 143(3), 282(1)(b)/(c)/ (d).]

Shipping Corporation of India v. DCIT (2025) 235 TTJ 163 / 173 taxmann.com 190 (Mum)(Trib)

S. 115V-I: Shipping business-Shipping income-Interest from deposits with banks-AO is directed to treat the interest income as part of the profits from core shipping activities carried on by the assessee as business income. [S.115VJ]

Shipping Corporation of India v. DCIT (2025) 235 TTJ 163 / 173 taxmann.com 190 (Mum)(Trib)

S. 115V-I: Shipping business-Shipping income-Allocation of administrative expenditure-Required to be allocated on a reasonable basis.

Munjal Auto Industries Ltd. v. ITO (2025) 235 TTJ 84 / 173 taxmann.com 498 (Ahd)(Trib)

S. 115JB: Company-Book profit-Sales tax subsidy-Credited to capital reserve-Adjustment made by the Assessing Officer is not justified.

Doraiswami Rajagopalan v. DCIT (2025) 235 TTJ 597 / 172 taxmann.com 735(SMC) (Bang)(Trib)

S. 112: Tax on long-term capital gains-Determination of tax in certain cases-Rate of tax-Redemption of debentures-Debentures are explicitly excluded from the concessional tax treatment under s. 112A, the correct rate of tax applicable on the LTCG from the redemption of market-linked debentures is 20 per cent under s. 112 [S.112A]

Vismruti Social & Charitable Trust v. CIT (E) (2025) 235 TTJ 590 / 172 taxmann.com 582 (Ahd)(Trib)

S. 80G: Donation-Charitable as well as religious objects-Trust applies less than 5 per cent of its income towards religious purposes-Matter is restored to the CIT(E) to consider the grant of registration after carrying out necessary verification in accordance with law. [S.80G(5) 80G(5B), Expiation 3.]