Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


ITO v. Vastimal Bhim Raj Sancheti (2025) 121 ITR 677 (Bang.)(Trib.)

S. 68: Cash credits Unsecured loan-Share application money-Identity, creditworthiness and genuineness proved-Assessee not required to explain source of source where creditor had sufficient own funds-Addition deleted. [S. 133(6)]

Goodview Marketing (P.) Ltd. v. ITO (2025) 121 ITR 8 / 172 taxmann.com 46 (Kol.)(Trib.)

S. 68: Cash credits-Revision of orders prejudicial to revenue-Cash credits-Share Capital-Share Premium-Second Reassessment-Natural justice-The material gathered was not furnished to the assessee, resulting in violation of section 142(3) and the principles of natural justice. Accordingly, the addition was deleted. [S. 142(3), 144, 147, 263]

Dy. CIT v. Kruti Lalitkumar Jain (2025) 121 ITR 26 (SN) (Pune)(Trib.)

S.54F: Capital gains-Investment in a residential house-Purchase of residential house-Deduction cannot be denied merely because the sale deed was executed subsequently where investment and genuineness of the transaction are established. [S. 45]

Computer Modelling Group Ltd. v. Asst. CIT (2025) 121 ITR 214 / 162 taxmann.com 437 (Delhi)(Trib.)

S. 44BB : Mineral oils-Computation-Non-Resident-Business Income-Permanent Establishment-Not taxable as business income-Interest under section 234B cannot be levied.-DTAA-India-Canada.[S.90, 209(1)(d), 234B]

Checkmate Services P. Ltd. v. Dy. CIT (2025) 121 ITR 73 (Ahd.)(Trib.)

S. 36(1)(va): Any sum received from employees-Employees’ contribution-Delay in deposit-Adjustment under section 143(1) valid-Auditor need not certify admissibility of claim. [S. 2(24) (x),37(1) 43B, 143(1)]

Shri Soudharma Brihad Tapogachchiya Tristutik Jain Sangha Samarpanam v. CIT (E) (2025) 170 taxmann.com 590 / 121 ITR 47 (SN) (Ahd.)(Trib.)

S. 12AB: Procedure for fresh registration-Trust for benefit of particular religious community-Registration rightly denied where objects are confined to the Jain community. [S. 11, 12, 12A, 12AA, 12AB(4), 13(1)(b)]

M. V. Karmari Charitable Trust v. CIT (E) (2025) 121 ITR 3 (SN) (Bang.)(Trib.)

S. 12AB: Procedure for fresh registration-Delay of 338 days in filing the appeal was condoned-Matter was remanded to the file of CIT(E) for passing a fresh order in accordance with law. [S. 11, 12, 253]

Institute Management Committee of Government ITI Peth v. ITO (2025) 121 ITR 76 (SN) (Pune)(Trib.)

S. 10 (23C): Educational institution-Exemption-Substantially financed by Government-CPC-Processing of return-Interest on Government grant-Public-private partnership-Denial of exemption was not justified. [S.10(23C(iiiab), 143(1)]

National Institute for Teacher Education v. ITO (2025) 121 ITR 72 (SN) (Guwahati)(Trib.)

S. 10 (23C): Educational institution-Exemption-Registration under S. 12A not mandatory-Addition was deleted..(S. 10(23C)(iiiad), 12A, 144)

Sumo Logic Inc. v. Asst. CIT (IT) (2025) 170 taxmann.com 756 / 121 ITR 78 (SN) (Delhi)(Trib.)

S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services-Non-resident-Make available-Cloud-based software-Tax Residency Certificate-The receipts were not chargeable to tax in India as fees for technical services-DTAA-India-USA. [Art. 12(4)]