Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


ITO v. Mayurbhanj Central Cooperative Bank Ltd. (2024) 230 TTJ 655 / 240 DTR 17 / 38 NYPTTJ 807 (Cuttack)(Trib)

S. 40A(7) : Expenses or payments not deductible-Gratuity-Fund maintained by LIC-Pendency of application-Matter is remanded to the file of AO for verification.[S.36(1)(vi)]

M.S. Hostel v. Dy.CIT (2024) 230 TTJ 575 / 38 NYPTTJ 392/ 167 taxmann.com 735 (Ahd) (Trib)

S. 40A(2): Expenses or payments not deductible-Excessive or unreasonable-Relative of partner-Service rendered is not doubted-No disallowance cannot be made.[S. 37(1)]

ITO v. Mayurbhanj Central Cooperative Bank Ltd. (2024) 230 TTJ 655 / 240 DTR 17 / 38 NYPTTJ 807 (Cuttack)(Trib)

S. 40(a)(ia): Amounts not deductible-Deduction at source-interest paid on the deposits-Co-operative bank-Finance Act, 2015 w.e.f. 1st June, 2015-Amendment is applicable prospectively w.e.f. 1st June, 2015 and not applicable for the relevant years-Deletion of disallowance is affirmed.[S.194A(3)(v)]

ITC Ltd v. ACIT (2024) 230 TTJ 921 / 38 NYPTTJ 626 (Kol)(Trib)

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Commission payment to foreign agents-Services rendered abroad-Not liable to tax in India-Not liable to deduct tax at source. [S.9(1)(i), 195]

ITC Ltd v. ACIT (2024) 230 TTJ 921 / 38 NYPTTJ 626 (Kol)(Trib)

S. 37(1) : Business expenditure-Capital or revenue-Registration charges of new and existing patents-Allowable as revenue expenditure.

Micro Labs Ltd v. ACIT (2023) 37 NYPTTJ 46/ (2024) 230 TTJ 625 (Bang)(Trib)

S. 35 : Expenditure on scientific research-Weighted deduction-In-house scientific research-Expenditure on clinical trials conducted outside approved-Clinical research outside facility would also be eligible for weighted deduction under S. 35(2AB). [S. 35(2AB]

ITC Ltd v. ACIT (2024) 230 TTJ 921 / 38 NYPTTJ 626 (Kol)(Trib)

S. 28(i) : Business loss-Market to market loss-Allowable as business expenditure.[S. 37(1)

ITC Ltd v. ACIT (2024) 230 TTJ 921 / 38 NYPTTJ 626 (Kol)(Trib)

S.14A : Disallowance of expenditure-Exempt income-Not possible to maintain separate books of account-The AO is directed to restrict the disallowance on a reasonable basis.[R.8D(2)(iii)]

Shri Gayatri Sanshodhan Seva Mandal v. CIT(E) (2024) 230 TTJ 777 / 240 DTR 65 / 38 NYPTTJ 710 (Pune) (Trib)

S. 12AB : Procedure for fresh registration-Registration granted cannot be cancelled without following due process of law-CIT(E) is directed to consider the assessee’s application under S. 12A(1)(ac)(v) in Form 10AB seeking approval for change in its objects/rules/ regulations as per the new trust deed and pass an order afresh in accordance with law.[S.12A(1)(ac)(v), 12AB(4), Form No. 10AB]

Swasthya Bikash Samity v. ITO (E) (2024) 230 TTJ 526 / 240 DTR 51 / 38 NYPTTJ 739 / 164 taxmann.com 756 (Cuttack) (Trib)

S. 10 (23C): Educational institution-Hospital-Controlled and funded by State Government-Matter remanded to the file of the AO de novo adjudication. [S. 10(23C)(iiiac)]