Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


City Union Bank Ltd. v. Dy. CIT (2024)112 ITR 337 /229 TTJ 139 (Chennai)(Trib)

S.14A : Disallowance of expenditure-Exempt income-Suo motu disallowance-Deletion of disallowance is justified.[R.D]

Bhartiya International Ltd. v. Dy. CIT (2024)112 ITR 207/ 227 TTJ 897 / 158 taxmann.com 239 / 38 NYPTTJ 18 (Delhi)(Trib)

S.14A : Disallowance of expenditure-Exempt income-Voluntary disallowance is exceeding actual exempt income-Disallowance is deleted. [R.8D]

Axis Bank Ltd. v. Asst. CIT (2024)112 ITR 28 (Ahd)(Trib)

S.14A : Disallowance of expenditure-Exempt income-Sufficient interest free funds-Disallowance is not justified.[R.8D]

Tapovan Education Trust v. CIT (2024)112 ITR 43 (SN)(Ahd)(Trib)

S. 12A : Registration-Trust or institution-Running Educational Institution-Denial of registration-Making profits-Matter restored to Commissioner for consideration of assessee’s application for registration de novo on merits-Delay is condoned.[S. 80G, 254(1)]

Idream Social Edtech Foundation v. CIT (E) (2024)112 ITR 20(Chd)(Trib)

S. 12A : Registration-Trust or institution-Details by questionnaire communicated through Electronic mode on Department’s Portal-Merely uploading of information about date of hearing on Income-Tax Portal is not effective service of notice-Notice is not served-Matter restored to Commissioner (E) to decide afresh in accordance with law after giving reasonable opportunity of being heard to assessee.[S. 12A(1)(1)(ac)(iii), 12AB, 282(1), R. 127(1)]

Shri Balaji Human Resources Development Trust v. ITO (2024)112 ITR 41 (SN)(Delhi)(Trib)

S. 11 : Property held for charitable purposes-Running business school-Payment to related party-Assessing Officer had not demonstrated how payment for business support services was not commensurate with market value of services availed of–Salary expenditure to faculty members-Disallowance for failure to file qualifications of teachers not sustainable-Disallowance is not warranted-Payment of commission to Consultants and counsellors is justified-Disallowance of expenses on computers to students is not reasonable. [S.12A 13(2)(c), 13(2)(c),13(2)(g), 13(3)]

Dawoodi Bohra Musafirkhana Trust v. ITO (E) (2024)112 ITR 8 (SN)(Ahd)(Trib)

S. 11 : Property held for charitable purposes-Corpus donations-Distinct and separate from income derived from property held under trust-Not entitled to exemption.[S. 2(24), 11(1(a), 11(1)(d), 12(1)]

Dy. CIT v.Sheriff Foundation (2024)112 ITR 72 (SN)(Delhi) (Trib)

S. 11 : Property held for charitable purposes-Donation to another trust with similar objects-Allowed as deduction in earlier years and latter years-Denial off exemption is not valid. [S.12A]

Toppan Merrill Technology Services P. Ltd. v. Dy. CIT (2024)112 ITR 32 (SN)(Chennai)(Trib)

S. 10A : Free trade zone-Reconciled entire figure and entire reconciliation matched amount declared in Form 56F-Claim is directed to be allowed. [Form No 56F]

Tech Mahindra Business Services Ltd. v. ACIT (2024)112 ITR 21 (SN)(Mum)(Trib)

S. 10A : Free trade zone-Eligible profits-Interest income-Income from business eligible for deduction-Foreign exchange gain on exchange earners’ foreign currency account-Allowable.