This Digest of case laws is prepared by KSA Legal and AIFTP from judgements reported in BCAJ, CTR, DTR, ITD, ITR, ITR (Trib), Chamber's Journal, SOT, Taxman, TTJ, BCAJ, ACAJ, www.itatonline.org and other journals
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S.87A: Rebate on Income-tax in case of certain individuals-Tax on short-term capital gains-Computation of income under S. 115BAC-No restriction in S. 111A which reflects the tax rate on short-term capital gains that the rebate under s. 87A would not be eligible for short-term capital gains.[S.111A]

Pramod Kumar Dubey v. ITO (2025) 237 TTJ 827 (SMC) (Agra) (Trib)

S.87A: Rebate on Income-tax in case of certain individuals-Tax on short-term capital gains-Computation of income under S. 115BAC-Amendment made by the Finance Act, 2025 supports the view that under the unamended provision applicable for asst. yr. 2024–25, rebate under S 87A cannot be denied merely because tax arises under s. 111A-The assessee is eligible for rebate under s. 87A for asst. yr. 2024-25 even though the income includes STCG taxable under s. 111A[S. 111A,112A(6), 115BAC]

Jayshreeben Jayantibhai Palsana v. ITO (2025) 237 TTJ 817 / 177 taxmann.com 411 (SMC) (Ahd)(Trib)

S. 80JJA: Bio-degradable waste-Collecting and processing-Belated filing of audit report requirement of furnishing the report of an accountant is mandatory-Procedural aspect The report of the Accountant in Form 10DA was available before the CPC at the time of passing intimation under S. 143(1), even though the same may not be filed on or before the due date of furnishing the same-The assessee is entitled to claim the deduction under S. 80JJAA [S.139(1), 143(1) Form No 10DA R.19AB]

IIFL Samasta Finance Ltd. v. DCIT (2025) 237 TTJ 870 / 176 taxmann.com 278 (Bang.)(Trib)

S. 80IC: Special category States-Profits and gains derived from industrial undertaking-Income from sale of scrap-Scrap was a by-product arising directly from the manufacturing process undertaken at the eligible unit-Eligible for deduction-Disallowance under S. 40(a)(ia) would form part of the eligible profits for the purpose of deduction under s. 80-IC, allowable deduction. [S.40(a)(ia)]

DCIT v. Reckit Benkiser Healthcare India (P) LTD. (2025) 237 TTJ 129 / 176 taxmann.com 573 (Ahd)(Trib)

S. 80IB: Industrial undertakings-Manufacture or production-Production of paints, varnish and thinners-Casual workers-The undertaking engaging ten or more workers-Entitled to exemption.

Jaydeep Petro Chem Company (P) Ltd. v. ITO (2025) 237 TTJ 316 / 176 taxmann.com 871 (Chennai) (Trib.)

S.80IA: Industrial undertakings-Enterprises engaged in infrastructure development-Claim was not made in the return-Additional ground before CIT(A)-The disputed claim of deduction under S. 80-IA(4) was neither made in the original return nor in any revised return till the conclusion of the assessment proceedings-Claim was made first time before CIT(A)-Additional ground was rejected-Not eligible for deduction.[S. 80A(5),80IA(4), 139(1), 139 (4), 250]

BSC C & C Joint Venture v. ACIT (2025) 237 TTJ 377(Delhi)(Trib)

S.80IA: Industrial undertakings-Enterprises engaged in infrastructure development-Sale of steam by one eligible unit to other eligible unit for captive consumption-Rejecting the comparable of the assessee and the enhancement made by the DRP by giving direction to treat the claim of deduction under s. 80-IA for steam transfer as ‘Nil’ is set aside-Claim of deduction is allowed.

Laxmi Organic Industries Ltd. v. DCIT (2025) 237 TTJ 268 / 177 taxmann.com 118 (Mum.)(Trib.)

S. 80G: Donation-Medical relief to the poor in rural areas-Rejection of application by CIT(E) is set aside and directed to approve. [S.2(15),80G(5)]

Matha Medical Centre Trust v. CIT(E) (2025) 237 TTJ 613 (Chennai)(Trib)

S. 80G: Donation-Recognition of institution, etc-CIT(E) has not brought any material on record to show that the activities of the assessee trust are not genuine or the conditions as specified above are not fulfilled by the assessee-trust-CIT(E) is directed to grant approval under s. 80G to the assessee-trust. [S.11, 12A, 80G(5)]

Academy of Liberal Education v. CIT(E) (2025) 237 TTJ 366 / 176 taxmann.com 675 (Bang) (Trib.)

S. 69C: Unexplained expenditure-Alleged bogus purchases-Produced documentary evidence such as purchase invoices, stock records, RTGS payments, GST returns, supplier confirmations, and segment-wise accounts-Matter was remanded back to the AO to obtain the bank account details of MT Co., and verify whether there exists any cash trail; if no such cashback trail is established upon verification, and payments are found to have remained within the banking system, then the addition is to be restricted only to the embedded profit element @ 5 per cent. [S. 145]

Leela Greenship Recycling (P) Ltd. v. DCIT (2025) 237 TTJ 471/ 180 taxmann.com 407 (Ahd)(Trib)