Half-Yearly Income Tax Case Digest: ITAT Decisions 2025 [Part VI]

Your ultimate guide for mastering TDS provisions - Click hereThis half-yearly round-up analytically summarizes the key Direct Tax-Income Tax rulings of the Income Tax Appellate Tribunal (ITAT) reported at Taxscan.in during the first half of 2025.

Assessment Issued in Name of Deceased Invalid: ITAT Remands Rs. 18.47 Cr addition for fresh adjudication

Beena JashwantbhaiPatel vs The Assistant Commissioner of Income Tax CITATION: 2025 TAXSCAN (ITAT) 749

The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) remanded the matter back to the Assessing Officer (AO) for fresh adjudication in a case where an assessment order was issued in the name of a deceased assessee. Beena Jashwantbhai Patel, legal heir of Late Shri Jaswantbhai Ishwarbhai Patel (assessee), had filed an appeal against the ex-parte order passed by the Commissioner of Income Tax (appeals) [CIT(A)] for Assessment Year 2019–20.

AO Fails to Properly Examine Rs. 1.27 Cr Co-operative Society Deposits: ITAT upholds PCIT’s Revision Order

Pavan PrabhudyalBhadada vs Income Tax Officer CITATION: 2025 TAXSCAN (ITAT) 748

The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) upheld the revisionary order passed by the Principal Commissioner of Income Tax (PCIT) due to the lack of enquiry by the Assessing Officer (AO) in Rs. 1.27 Cr deposits by Co-operative Society. Pavan Prabhudyal Bhadada (assessee), in search and seizure action on Shri Renuka Mata Multi State Urban Co-operative Society revealed that the assessee had deposited Rs. 1,27,75,311 in an account maintained with the society.

Advances given in Return for an Advantage by the Shareholder is not Dividend u/s 2(22)(e): ITAT

Subhash Chander Oberoivs ACIT CITATION: 2025 TAXSCAN (ITAT) 752

The Mumbai Bench of Income Tax Appellate Tribunal (ITAT) has held that advances which are in the nature of commercial transactions would not fall under the purview of the “advance” in Section 2(22)(e) of the Income Tax Act, 1961 and shall not be considered as deemed dividend. The assessee, Subhash Chander, is a proprietor of M/s Paros Corp and is a shareholder holding 35% shares in M/s AGIV India Pvt Ltd. which deals in Broadcast system integration with intellectual capabilities and other business interests and facilities. M/s AGIV India Pvt. Ltd. was developing a joint venture project with IND-AGIV Commerce Ltd. and RST Technologies Ltd. and held 72% shares in IND-AGIV Commerce Ltd. and 90% shares in RST Technologies Ltd.

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ITAT Allows NDTV’s Business Expense Claims, Quashes Section 14A Disallowance

NDTV Networks Ltd vsDCIT, Circle-18(1) CITATION: 2025 TAXSCAN (ITAT) 753

In a significant relief for NDTV, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has partly allowed the company’s appeal for the Assessment Year 2014–15. The Tribunal set aside disallowances related to business expenses and Section 14A, while remanding the issue of directors remuneration back to the Assessing Officer for fresh verification. The appellant, NDTV Networks Ltd., had challenged the order passed by the Commissioner of Income Tax (Appeals)-6, Delhi, dated 28 August 2018, which upheld disallowances made by the Assessing Officer under Sections 37(1) and 14A of the Income Tax Act, 1961.

Failure to Establish Source of Income: ITAT restricts Addition of Income to 25%

Shri SundarrajanVenkateshkumar vs ITO CITATION: 2025 TAXSCAN (ITAT) 754

The Chennai bench of Income Tax Appellate Tribunal (ITAT) has recently restricted the addition of unestablished income to 25% noting that the assessee failed to establish the source of the said income amounting to ₹13.39 lacs.

GST Collected by Foreign Company not to be Included in Gross Receipts for Computation of Income u/s 44BB: ITAT

OceaneeringInternational GMBH vs Deputy Commissioner of Income-tax (InternationalTaxation) CITATION: 2025 TAXSCAN (ITAT) 755

The Income Tax Appellate Tribunal ( ITAT ) bench of Mumbai has ruled that the GST (Goods and Services Tax) collected by the foreign company is excluded from Gross Receipts for calculating income under Section 44BB of the Income Tax Act, 1961. The issues raised by the appellant, Oceaneering International GMBH is the inclusion of GST in the computation of presumptive income under Section 44BB of the Income Tax Act. Oceaneering International GMBH, a non-resident company registered in Switzerland, specializes in providing equipment and services for oil and gas drilling operations to companies engaged in exploration activities in India.

ITAT Allows Section 80P Deduction for Kerala University Co-op Society’s Bank Interest Income

The Income Tax Officervs Kerala University Employees Co-operative Society Ltd CITATION: 2025 TAXSCAN (ITAT) 758

The Income Tax Appellate Tribunal (ITAT) has ruled in favor of the Kerala University Employees Co-operative Society Ltd., granting it a deduction under Section 80P for interest income earned from investments with the District Co-operative Bank, State Bank of India (SBI), and the Treasury. The decision was made in an appeal against the order passed by the National Faceless Appeal Centre (CIT(A)) for the Assessment Year 2020-21. The dispute arose after the Income Tax Officer (ITO) issued an assessment order for the year 2020-21, disallowing the exemption claimed by the co-operative society on interest income earned from these investments. The ITO had denied the deduction, arguing that the income derived from these banks and institutions did not qualify for a deduction under Section 80P, as the society was considered a co-operative bank.

ITAT Sets Aside CIT(A) Order on Kochin Co-op Society’s Cash Deposits, Demands Fresh Review

The Income Tax Officervs Kochin Co-Operative SocietyLtd. CITATION: 2025 TAXSCAN (ITAT) 759

In a recent ruling, the Income Tax Appellate Tribunal (ITAT) has set aside the order passed by the Commissioner of Income Tax (Appeals) [CIT(A)] in the case of Kochin Co-operative Society Ltd. regarding the unexplained cash deposits made by the society. The case pertains to the Assessment Years 2013-14 and 2014-15. The Revenue, represented by the Income Tax Officer, had filed appeals against the CIT(A)’s orders dated 20th July 2023 and 25th July 2023. The appellant contended that the CIT(A) had erred in accepting the explanation provided by the respondent society regarding the source of the cash deposits, which amounted to Rs. 2,39,82,500. The assessing officer had initiated proceedings under Section 148 of the Income Tax Act, suspecting that income had escaped assessment. Subsequently, a best judgment assessment was conducted under Section 144 due to the failure of the society to file a return of income under Section 139(1).

ITAT Remands ₹5.41 Cr TDS Disallowance on US Remittance for Reassessment Under India-US DTAA

Sunku SatyanarayanaSanjay vs The Deputy Commissioner of Income Tax CITATION: 2025 TAXSCAN (ITAT) 760

The Income Tax Appellate Tribunal (ITAT) Bengaluru recently set aside a ₹5.41 crore TDS disallowance on payments made to a US-based entity for business development and marketing services and directed it to reassess according to the provisions of India-US Double Taxation Avoidance Agreement (India-US DTAA). Sunku Satyanarayana Sanjay (assessee-appellant) was engaged in the export of software development and testing services through his proprietary concern, Versatiletech.

ITAT Confirms ₹4.10 Cr Addition U/s 69, Upholds Courts’ Authority to Dismiss Defaulted Cases

Sureshbhai RaghubhaiThorat vs The ITO CITATION: 2025 TAXSCAN (ITAT) 761

In a recent judgment, the Income Tax Appellate Tribunal (ITAT) of Surat upheld the addition made by the Assessing Officer (AO) under section 69 of the Income Tax Act, 1961, as the assessee failed to appear and respond despite repeated notices being issued. Sureshbhai Raghubhai Thorat (assessee-appellant) failed to file the income tax return for the Financial Year (FY) 2017-18. Due to this non-compliance, a survey was conducted by the Income Tax Department. During the survey, the authorities discovered a notarized agreement indicating the assessee’s ₹4.10 crore investment in a project.

ITAT Rules in Favor of NSE: Rs 170 Crore SGF Contribution Allowable as Business Expense

National StockExchange of India Ltd. vs Principal Commissioner of Income Tax–7 CITATION: 2025 TAXSCAN (ITAT) 757

The Income Tax Appellate Tribunal (ITAT), Mumbai Bench has allowed the appeal filed by National Stock Exchange of India (NSE) against the revisionary order passed by the Principal Commissioner of Income Tax-7 (PCIT) under section 263 of the Income Tax Act, 1961. The appeal pertained to Assessment Year 2015–16 and challenged the disallowance of Rs 170 crore contributed by NSE to the Core Settlement Guarantee Fund (Core SGF) maintained by the National Securities Clearing Corporation Ltd. (NSCCL). The appellant had filed its return of income declaring total income of Rs 968.20 crore, which was assessed at Rs 968.33 crore by the Assessing Officer (AO) under section 143(3) of the Act. Later, the PCIT initiated revisionary proceedings under section 263 on the ground that the AO failed to properly examine the deductibility of the Rs 170 crore contribution to Core SGF, terming it a contingent liability.

No Income Tax Payable on New Flat Received in Exchange for Old One: ITAT deletes Addition u/s 56(2)(x)

Anil Dattaram Pitalevs Income Tax Officer-16(2)(1) CITATION: 2025 TAXSCAN (ITAT) 762

In a recent ruling, The Income Tax Appellate Tribunal ( ITAT ) of Mumbai ruled that income tax is not applicable under Section 56(2)(x) of the Income Tax Act, 1961, where a new flat is received in exchange for an old one as part of a redevelopment project. The bench deleted additions made by the authorities. The assessee, Anil Dattaram Pitale had originally purchased a flat—Flat No. C-5/28 in Mahavir Nagar Tristar Co-operative Housing Society—during the financial year 1997–98. Subsequently, the housing society entered into a redevelopment agreement with a developer. As per the terms of the redevelopment, the assessee surrendered his old flat and received a new flat—Flat No. B-1102—through a registered agreement dated December 26, 2017. The stamp duty value of the new flat was determined to be ₹25,17,700, while the indexed cost of acquisition of the old flat stood at ₹5,43,040.

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ITAT Quashes Assessment Order as Notice u/s 143(2) Sent to Wrong Address

Dhanottam VasantLonkar vs Income Tax Officer CITATION: 2025 TAXSCAN (ITAT) 763

The Income Tax Appellate Tribunal (ITAT) Pune Bench has quashed the assessment order passed against the assessee on the ground that the notice under Section 143(2) of the Income Tax Act, 1961 was issued at an incorrect address and therefore not validly served within the prescribed statutory time limit. The appellant, Dhanottam Vasant Lonkar, had filed his return of income for Assessment Year 2013-14 declaring a total income of Rs.1,76,25,230. His case was selected for scrutiny under CASS, and a notice under Section 143(2) dated 3 September 2014 was issued by the Assessing Officer (AO). The AO claimed that the notice was sent through RPAD to the address “268A, Shivaji Nagar, Pune – 411005.” However, the appellant contended that he never resided at that address and that his correct address, as mentioned in his PAN database and return of income, was “301, Kamala Residency, CTS No.1050, Model Colony, Pune – 411016.” He argued that he had never received the notice under Section 143(2) and that therefore, the assessment proceedings were invalid and void ab initio.

Exempt LTCG under India-Mauritius DTAA cannot be Adjusted against Taxable Losses: ITAT

Bay Capital India FundLimited vs Additional Director Of Income Tax CITATION: 2025 TAXSCAN (ITAT) 764

Top Stories Exempt LTCG under India-Mauritius DTAA cannot be Adjusted against Taxable Losses: ITAT [Read Order] The Tribunal noted that adjusting taxable losses against exempt gains would result in indirectly taxing exempt income, which would violate the provisions of the DTAA and Section 90(2) of the Act By Adwaid M S - On April 18, 2025 11:09 am - 2 mins read The Income Tax Appellate Tribunal (ITAT) Mumbai Bench has held that long-term capital gains (LTCG) exempt under the India-Mauritius Double Taxation Avoidance Agreement (DTAA) cannot be adjusted against taxable short-term or long-term capital losses incurred by the assessee. The appellant, Bay Capital India Fund Limited, a company incorporated in Mauritius and registered as a Foreign Portfolio Investor with SEBI, filed its return of income for Assessment Year 2019–20 declaring nil income and carried forward capital losses aggregating to Rs.3,59,84,420 (3.59 crore).

ITAT Sets Aside Ex-Parte Orders Passed Without Considering Objections to Mechanical Reopening

Aldiablos InfotechPvt.Ltd. vs The I.T.O CITATION: 2025 TAXSCAN (ITAT) 767

Top Stories ITAT Sets Aside Ex-Parte Orders Passed Without Considering Objections to Mechanical Reopening [Read Order] The Tribunal observed that non-consideration of objections and passing of non-speaking orders violated the principles of natural justice By Adwaid M S - On April 18, 2025 12:27 pm - 2 mins read The Income Tax Appellate Tribunal (ITAT) Ahmedabad Bench has set aside the ex-parte orders passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, holding that objections raised against mechanical reopening of assessment were not considered and remanded the matters for fresh adjudication.

ITAT Validates AO’s Estimation of Gross Profit at 20.97% for Road Contractor Amidst Unverifiable Cash Transactions

Sarandhar UmashankarGupta vs Assistant Commissioner of Income Tax CITATION: 2025 TAXSCAN (ITAT) 766

The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) upheld the rejection of books of accounts of a road contractor, and confirmed the addition of ₹40 lakh on account of unverifiable and inadequately documented cash transactions. The appeal arose from an order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), pertaining to Assessment Year (AY) 2017–18. The assessee, Sarandhar Umashankar Gupta, a government contractor engaged in road maintenance work, had challenged the CIT(A)’s decision to uphold the rejection of his books under Section 145A of the Income Tax Act and the resultant addition based on estimated gross profit.

ITAT Dismisses Department’s Appeal, Upholds 5% Bogus Purchase Addition & Deletes Penalty

Income Tax Officer vsBorda Brothers CITATION: 2025 TAXSCAN (ITAT) 768

The Income Tax Appellate Tribunal (ITAT) Surat Bench has dismissed the Department’s appeals, confirming the restriction of bogus purchase addition to 5% and deletion of penalty under Section 271(1)(c) of the Income Tax Act, 1961. The appellant, Borda Brothers, a firm engaged in the diamond trade, had filed its return of income for Assessment Year 2007-08 declaring total income of Rs.43,17,209. The case was reopened under Section 148 based on information from search operations conducted on the Rajendra Jain Group, which was found engaged in providing accommodation entries. The Assessing Officer concluded that Borda Brothers had made bogus purchases from entities linked to the Rajendra Jain Group and made an addition of Rs.9,64,13,991 under Section 69A. In appeal, the Commissioner of Income Tax (Appeals) restricted the addition to 5% of the bogus purchases based on the assessee’s business reality and the consistent approach adopted in earlier years.

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ITAT Allows Appeal, Deletes Unexplained Cash Addition of Rs.3.45 Lakh Citing Agricultural Income & Bank Withdrawal Proof

Asifiqbal IsmailJangda vs Income Tax Officer CITATION: 2025 TAXSCAN (ITAT) 770

The Income Tax Appellate Tribunal (ITAT) Surat Bench has deleted an addition of Rs.3,45,000 made towards unexplained cash deposits, accepting the assessee’s explanation supported by agricultural income documents and proof of earlier bank withdrawals. The appellant, Asifiqbal Ismail Jangda, had filed his return of income for Assessment Year 2017-18 declaring Rs.2,71,610. The case was selected for limited scrutiny to verify cash deposits during the demonetisation period amounting to Rs.3,45,000. The Assessing Officer noted that the assessee had deposited Rs.1,45,000 in his HDFC Bank account and Rs.2,00,000 in his Indian Bank account. Since no agricultural income was declared in the return for the year, the Assessing Officer treated the deposits as unexplained under Section 69A of the Income Tax Act and added them to the total income.

ITAT Remands 80P Deduction Case to CIT(A), Directs Fresh Hearing for Co-op Society

Grameena Seva SahakariSangha Niyamita vs I T O, National e Assessment Centre CITATION: 2025 TAXSCAN (ITAT) 769

The Income Tax Appellate Tribunal (ITAT) Panaji Bench has set aside the ex-parte order passed by the Commissioner of Income Tax (Appeals) and remanded the matter for fresh adjudication, directing a fresh hearing on the eligibility of deduction claimed under Section 80P by the co-operative society. The appellant, Grameena Seva Sahakari Sangha Niyamita, a cooperative credit society located in Karnataka, filed its return of income for Assessment Year 2014-15, declaring a total income of Rs.97,420 after claiming deduction of Rs.27,55,833 under Section 80P of the Income Tax Act, 1961. The original assessment was completed under Section 143(3) allowing the deduction. Subsequently, the Assessing Officer reopened the assessment under Section 147 on the ground that the assessee was not eligible for deduction under Section 80P and passed the reassessment order denying the claim, assessing the income at Rs.28,53,250.

ITAT Grants Relief in Trust Registration Case Despite Procedural Defaults, Subject to Conditions

Surat Sewa Foundationsvs The CIT(Exemption) CITATION: 2025 TAXSCAN (ITAT) 772

In a recent decision, the Surat bench of the Income Tax Appellate Tribunal (ITAT) overturned a decision by the Commissioner of Income Tax (Exemption) ( CIT(E) ) that canceled the Appellant-Assessee trust’s registration, despite the trust’s delay in submitting the required documents. Surat Sewa Foundations, the assessee trust, has already been provisionally registered under the Income Tax Act of 1961. The trust was then directed to submit the necessary documents to the CIT(E) to prove its genuineness and activities.

ITAT Condones 27-Day Delay and Accepted Trust’s Appeal u/s 80G Following CBDT Circular

Surat Sewa Foundationsvs The CIT(Exemption) CITATION: 2025 TAXSCAN (ITAT) 772

In a recent ruling, the Surat Bench of the Income Tax Appellate Tribunal ( ITAT ) condoned a delay of 27 days and allowed reconsideration of a trust’s application for registration under Section 80G of the Income Tax Act, 1961. Surat Sewa Foundation (assessee), a trust formed on 01.12.2021, received provisional registration under Sections 12A and 80G of the Income Tax Act, 1961. It applied for regular registration on 27.10.2023 but failed to respond to notices from the Commissioner of Income Tax (Exemption) (CIT(E)), leading to rejection of its applications.

ITAT Upholds Penalty Reduction u/s 275(1A) Despite Pending HC Appeal

The DCIT vs SunitSudhirbhai Chokshi CITATION: 2025 TAXSCAN (ITAT) 771

In a significant ruling, the Income Tax Appellate Tribunal (ITAT), Ahmedabad, held that Section 275(1A) permits the Assessing Officer (AO) to revise penalties in line with assessment changes directed by appellate authorities or courts even though the appeal is still pending. The assessee, Sunit Sudhirbhai Chokshi, was assessed at ₹23,87,99,020 for the Assessment Year (A.Y.) 2017-18 and 2018-19, based on differences between the returned and assessed income. A penalty of ₹28,088,610 was imposed by the AO under section 271AAB of the Income Tax Act, 1961, on the additions.

Relief for Bank of Baroda: ITAT Rules MAT Provisions u/s 115JB Not Applicable

M/s. Bank of Baroda vsAddl. CIT CITATION: 2025 TAXSCAN (ITAT) 773

The Bangalore Bench of Income Tax Appellate Tribunal ( ITAT ) granted relief to Bank of Baroda by holding that the Minimum Alternate Tax ( MAT ) provisions under Section 115JB of the Income Tax Act,1961 do not apply to it. Bank of Baroda, appellant-assessee, filed its return for AY 2015-16 on 28.9.2015, showing no income. It later revised the return, claiming an additional Rs. 200 crores deduction under section 36(1)(vii), still reporting no income. The case was selected for scrutiny, and notices were issued for verification.

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Arvindo Trust Scam Fallout: ITAT Dismisses Appeal Against Disallowance of Bogus Research Donation

Brightech Valves &Controls Pvt. Ltd vs Deputy Commissioner of Income Tax CITATION: 2025 TAXSCAN (ITAT) 765

The Income Tax Appellate Tribunal (ITAT) Ahmedabad Bench “SMC” has dismissed the appeal filed against the disallowance of a deduction claimed on a donation made to the Arvindo Institute of Applied Scientific Research, citing that the donation was part of a bogus transaction. The appellant, Brightech Valves & Controls Pvt. Ltd., had filed its return of income for Assessment Year 2012-13 declaring a total income of Rs.28,22,430. The Assessing Officer reopened the assessment after receiving information that Arvindo Institute of Applied Scientific Research was found not to be engaged in genuine research activities. The trustee of the institute, Umesh C. Nagda, during a statement recorded under Section 131 of the Income Tax Act, admitted that the trust was issuing false donation receipts and was not recognized as an approved research institution under Section 35(1)(ii). The appellant had donated Rs.5,00,000 to the said trust and claimed a weighted deduction of Rs.8,75,000 under Section 35(1)(ii), which was disallowed by the Assessing Officer during the reassessment proceedings.

Win for WOW Entertainment: ITAT Deletes ₹1.44 Cr S.68 Addition Over Denial of Cross-Examination and Proven Loan Genuineness

Wow Entertainment andMedia Private Limited vs Assistant Commissioner of Income Tax CITATION: 2025 TAXSCAN (ITAT) 774

The Mumbai Bench of Income Tax Appellate Tribunal (ITAT) ruled in favor of WOW Entertainment and Media Private Limited, deleting a ₹1.44 crore addition under Section 68 of Income Tax Act,1961 over denial of cross-examination and proven loan genuineness Wow Entertainment and Media Private Limited,appellant-assessee,filed its return of income on 14.03.2019, declaring ₹65,15,970. The case was selected for scrutiny, and notices were issued.During the assessment, the Assessing Officer (AO) found that the company had shown an unsecured loan of ₹1.44 crore (₹1.4 crore as principal and ₹4.67 lakh as interest) from Dhyaneshwari Multistate Urban Cooperative Credit Society Ltd. Several questions were raised regarding the source, purpose, and terms of the loan.

Penalty u/s 270A for Misreporting without Proper Charge Specification Invalid: ITAT Deletes Rs. 38.05 Lakh Penalty

Mr. Nateshan SampathNo.06 vs DCIT CITATION: 2025 TAXSCAN (ITAT) 775

The Bangalore Bench of the Income Tax Appellate Tribunal (ITAT)deleted the penalty of Rs. 38.05 lakh imposed on the assessee due to the failure of the Assessing Officer (AO) to clearly specify the charge whether for under-reporting or misreporting of income. Nateshan Sampath (assessee), had not filed a return of income for Assessment Year 2018–19. The AO issued notice and the assessee filed a return of income declaring loss of Rs. 1,02,80,375 from business and long term capital gains of Rs. 20,68,361 from sale of immovable property.

Religious Objects must be Assessed under 5% Expenditure Rule: ITAT restores 80G Application

Vismruti Social AndCharitable Trust vs Commissioner of Income Tax (Exemption) CITATION: 2025 TAXSCAN (ITAT) 778

The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) restored the matter for fresh adjudication which is to be assessed at 5% Expenditure rule in a case where the Commissioner of Income Tax (Exemption) [CIT(E)] had rejected the assessee trust’s application for approval under Section 80G of the Income Tax Act, citing the presence of religious objects in the trust deed. Vismruti Social and Charitable Trust (assessee) had applied for registration under Section 80G(5)(iii). The CIT(E) rejected the application on the ground that two of the trust’s objects publishing literature and organizing events related to Sanatan Dharma were religious in nature.

Bogus Purchases of ₹2.5 Crore: ITAT applies 4% GP Rate citing Taxpayer’s Declared Profit

Income-tax Officer vsMr. Deepak JagshibhaiVisaria CITATION: 2025 TAXSCAN (ITAT) 777

The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) upheld the order of the Commissioner of Income Tax (Appeals) [CIT(A)], which restricted the addition on account of bogus purchases to 4% of the purchase value. Deepak Jagshibhai Visaria (assessee) who was alleged to have made bogus purchases which amounted to Rs. 2,50,59,386. The Assessing Officer (AO) based on information received from the Maharashtra Sales Tax Department, treated purchases of ₹2,50,59,386 as bogus and made an addition of ₹31,32,423 by applying a gross profit rate of 12.5%.

CIT(A) grants Relief on Interest Disallowance for Advances to Sister Concerns: ITAT Orders Verification of Funds Flow

Deputy Commissioner ofIncome Tax vs Oswal Extrusion Ltd CITATION: 2025 TAXSCAN (ITAT) 780

The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) directed the CIT(A) to verify the funds flow statement before allowing relief in a case concerning disallowance of interest on advances made to sister concerns. Oswal Extrusion Ltd. ( assessee), advanced Rs. 30 crores to HCP Enterprise Ltd. and Rs. 50 lakhs to Prasthan Infrastructure Ltd., both of which were stated to be its sister concerns. The Assessing Officer (AO) observed that the assessee had incurred interest expenditure of Rs. 933.52 lakhs but had not charged any interest on the advances.

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S. 143 Assessment Void Ab Initio: ITAT Rules AO Misapplied Jurisdiction Despite Satisfaction Note u/s 153C

REENA MITTAL vs DCIT CITATION: 2025 TAXSCAN (ITAT) 776

The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) quashed the assessment framed under Section 143 of the Income Tax Act, ruling it as void due to misapplied jurisdiction by the Assessing Officer (AO). Reena Mittal, (assessee) in the case where the AO made an addition of Rs. 2,03,03,850. Aggrieved by the AO’s order, the assessee filed an appeal before the CIT(A). The assessee challenged the validity of the assessment order for Assessment Year 2021–22 passed under Section 143(3) of the Income Tax Act.

Failure to Adjudicate AO’s Jurisdictional Grounds: ITAT Remands Matter to CIT(A)

M/s Ashta VinayakEstate vs Assistant Commissioner of Income Tax CITATION: 2025 TAXSCAN (ITAT) 779

The Raipur Bench of the Income Tax Appellate Tribunal (ITAT) remanded the matter to the CIT(A) for fresh adjudication after observing that the CIT(A) failed to address the preliminary jurisdictional objections raised by the assessee against the assessment proceedings. Ashta Vinayak Estate (assessee) is a firm which has filed return of income declaring total income of Rs. 1,22,97,810. The Assessing Officer (AO) issued notices seeking details of sales & purchases of lands and to substantiate short-term capital gain.

ITAT sets aside Addition of Rs. 45.74 Lakh Cash Deposit during Demonetisation, Remands matter for fresh Examination

Trichur Heart HospitalLtd vs Dy. Commissioner of Income Tax CITATION: 2025 TAXSCAN (ITAT) 781

The Cochin Bench of the Income Tax Appellate Tribunal (ITAT), set aside an addition of Rs. 45.74 lakh made by the assessing officer (AO) on cash deposits in specified bank notes (SBN) during the demonetisation period. The bench has remanded the matter to the Assessing Officer (AO) for fresh examination. Coming to the facts of the present case, for the assessment year (AY) 2017-18, the hospital assessee named Trichur Heart Hospital Ltd had filed its income tax return declaring an income of Rs. 1.69 crore. After that, the AO completed the assessment at Rs. 2.15 crore, adding Rs. 45.74 lakh as unexplained cash deposits made during demonetisation period. The AO was of the strong opinion that the hospital was not authorised to accept SBN after November 9, 2016. The Commissioner of Income Tax (Appeals) upheld the AO’s decision.

Relief to Oriental Insurance: ITAT Upholds Deletion of Rs. 21.36 Crore Disallowance u/s 14A

ACIT vs The OrientalInsurance Co. Ltd CITATION: 2025 TAXSCAN (ITAT) 782

The Delhi bench of the Income Tax Appellate Tribunal (ITAT) has upheld the deletion of Rs. 21.36 crore disallowance under Section 14A of the Income Tax Act, 1961. In this case, the revenue has appealed against the order of the Commissioner of Income Tax (Appeals) [CIT(A)] for the Assessment Year (AY) 2018-19. The assessee had also filed cross-objections against the order of CIT (A) dated 15.09.2023 for the AY as mentioned earlier.

‘Clear-Cut Case of Concealment’: ITAT Upholds Penalty Under Section 271(1)(c) for Rs 2.65 Crore Bogus Share Capital

UGS Finance Pvt. Ltdvs DCIT CITATION: 2025 TAXSCAN (ITAT) 783

The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has upheld a penalty of Rs. 95,10,463 imposed under Section 271(1)(c) of the Income Tax Act, 1961, on the assessee, UGS Finance Pvt. Ltd. for concealing income through bogus share capital transactions amounting to Rs. 2.65 crore by observing that it was a clear-cut case of concealment. For the assessment year 2004-05, the Assessing Officer (AO) reopened proceedings under Section 148 based on information from the Central Economic Intelligence Bureau (CEIB) that the assessee had issued shares at a premium of Rs. 90 per share (face value Rs. 10), but investigations revealed that the transactions were conducted to route unaccounted money.

No Clear Finding on Merits: ITAT Directs CIT(A) to Decide the Matter Afresh

Sudhanshu Rastogi vsACIT CITATION: 2025 TAXSCAN (ITAT) 784

The Lucknow bench of Income Tax Appellate Tribunal (ITAT) has recently restored a case of an assessee to the file of the Commissioner of Income Tax (Appeals) in the absence of any clear findings on the merits of addition of income. The assessee filed his return of income declaring a total income of ₹18,03,210 in the status of individual. The case was selected for scrutiny through Computer Assisted Scrutiny Selection (CASS) and a notice was issued to the assessee u/s 143(2) of the Income Tax Act, 1961. In response to the statutory notices, the assessee furnished the requisite information but the information was not found to be satisfactory. Therefore, the cash deposited in the bank account amounting to Rs.43,00,000/- was treated as unexplained income by the Assessing Officer.

“Adequate and Effective Opportunity of Being Heard must be Provided”: ITAT Remands the Case to Assessing Officer

Swastik Enterprises vsITO CITATION: 2025 TAXSCAN (ITAT) 785

The New Delhi bench of the Income Tax Appellate Tribunal (ITAT) passed an order remanding the case of the assessee to the Assessing Officer (AO) with directions to pass an order after providing effective and adequate opportunity of being heard. The assessee, Swastik Enterprises, is a partnership firm engaged in the business of trading of Iron and Steel scrap from its business places at New Delhi and Gurgaon. The assessee makes purchases majorly from the automobile sector which are then sold in bulk and retail to scrap melting units and steel manufacturing companies.

Opportunity of Being Heard Must be Provided: ITAT Remits Ex-Parte Order to AO

SOHANVIR SINGH vs ITO CITATION: 2025 TAXSCAN (ITAT) 787

The New Delhi bench of Income Tax Appellate Tribunal (ITAT) has remitted the case of the Assessee back to the file of the Assessing Officer to decide the matter afresh after giving to the assessee an adequate opportunity of being heard. The assessee filed an appeal against the order of Commissioner of Income Tax (Appeals)/ National Faceless Assessment Centre (NFAC), Delhi dated 05.09.2023 relating to assessment year 2017-18.

Approval Memo u/s 153D Silent on Issues Involved not Sustainable in Law: ITAT quashes ₹32L Income Tax Addition

Inder Chand Bajaj vsDCIT CITATION: 2025 TAXSCAN (ITAT) 788

The Delhi bench of Income Tax Appellate Tribunal (ITAT) has quashed an assessment order on the ground of an erroneous and non-speaking approval granted by the Additional Commissioner of Income Tax (Appeals) [CIT(A)] to the Deputy Commissioner of Income Tax under Section 153D of the Income Tax Act, 1961. Assessment proceedings were initiated against the assessee pursuant to a search and seizure operation dated 20.04.2017. Consequently, an assessment order was passed on 18.12.2019 under Section 143(3) read with Section 153A of the Income Tax Act,1961 by making an addition of ₹32,41,00 under Section 68 of the Act,1961.

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ITAT disallows Tax Deduction claimed u/s 35(1)(ii) for Donation to Unapproved Scientific Research Trust

Parag Dave vs TheDeputy Commissioner of Income Tax CITATION: 2025 TAXSCAN (ITAT) 790

In a recent judgment, the Ahmedabad bench of the Income Tax Appellate Authority (ITAT) set aside the deduction claim of an assessee for the donation made by him to an unapproved scientific authority. The assessee, Parag Dave, was engaged in testing of soil, building materials, conducting survey work, etc. On 26.09.2017, the assessee filed his return declaring a total income of ₹56,55,070. During the scrutiny assessment, it was observed that he claimed a weighted deduction of ₹54,25,000 under Section 35(1)(ii) of the Income Tax Act, 1961, for a donation of ₹31,00,000 made to Shri Arvindo Institute of Applied Scientific Research Trust.

ITAT rejects Income Tax Department’s Algorithm-Based Tax Addition in Cash Deposit Made During Demonetization Period

Income Tax Officer vsBimal Jewellers CITATION: 2025 TAXSCAN (ITAT) 789

In a recent ruling, the Delhi bench of the Income Tax Appellate Tribunal (ITAT) upheld the Commissioner of Income Tax (Appeals) [CIT(A)]’s decision to delete the ₹1.63 crore addition made by the Assessing Officer (AO) on cash deposits during the demonetization period, holding that the addition based on algorithmic analysis and speculative assumptions lacked concrete evidence. The assessee, Bimal Jewellers, was engaged in the business of purchasing and selling gold. During the financial year (F.Y.) 2016-17, the assessee deposited ₹2,19,60,000 in cash into two bank accounts maintained with HDFC Bank and Bank of Baroda. Out of this, ₹1,97,00,000 was deposited during the demonetization period.

Cash Deposits Were Duly Recorded in NBFC’s Books: ITAT Deletes Rs. 14.84 Lakh Addition

M/s Savery TransportFinance Limited vs ACIT CITATION: 2025 TAXSCAN (ITAT) 794

The Chennai Bench of the Income Tax Appellate Tribunal (ITAT) deleted the addition of Rs. 14.84 lakhs made under Section 69A of the Income Tax Act, 1961, on the grounds that the cash deposits in question were duly recorded in the books of account maintained by a registered non-banking financial company (NBFC), Savery Transport Finance Ltd. Savery Transport Finance Ltd., the assessee, is a registered NBFC engaged in the business of financing commercial vehicles. For the Assessment Year 2017–18, the assessee filed its return declaring income under the normal provisions and also under the Minimum Alternate Tax (MAT) regime. During the demonetization period from 9 November 2016 to 30 December 2016, the assessee deposited Rs. 15.87 crore in cash, of which Rs. 14.84 lakhs were in Specified Bank Notes (SBNs).

ITAT Sets Aside Rejection of 12A Registration After Finding Trust’s Objects Not Confined to Caste

Patidar Samaj TrustKhajurdi vs Commissioner of Income Tax (Exemption) CITATION: 2025 TAXSCAN (ITAT) 793

The Income Tax Appellate Tribunal (ITAT) Ahmedabad has overturned the rejection of a Trust’s application for registration under Section 12A of the Income Tax Act, 1961, ruling that the trust’s charitable activities were not restricted to a specific caste. The bench, comprising Judicial Member Suchitra Kamble and Accountant Member Narendra Prasad Sinha, directed the Commissioner of Income Tax (Exemption) to reconsider the matter in light of legal precedents. Patidar Samaj Trust Khajurdi had appealed against the CIT (E)’s order which denied its registration under Section 12A, citing that six of its eleven objects primarily benefited the Patidar community. The CIT (E) had invoked Section 13(1)(b) of the Act, which restricts exemptions for trusts serving a particular religious or caste-based group. However, the trust argued that its seventh object explicitly aimed to assist distressed individuals “without caste and creed,” demonstrating a broader charitable intent.

ITAT Clarifies Disallowance u/s 14A of Income Tax is Permissible Even without Exempt Income

Sapphire Foods IndiaLimited vs DCIT CITATION: 2025 TAXSCAN (ITAT) 795

The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) upheld the disallowance of expenditure under Section 14A of the Income Tax Act, 1961, clarifying that disallowance is permissible even in the absence of exempt income from Assessment Year 2022–23 onwards, following the amendment introduced by the Finance Act, 2022. Sapphire Foods India Ltd., the assessee, is a prominent operator of KFC and Pizza Hut restaurant chains in India. For the Assessment Year 2022–23, the assessee filed a revised return of income declaring NIL income.

ITAT Ahmedabad Orders Rectification After Wrong Consideration of Depreciation as Net Profit

M/s. Gujarat StateAviation Infrastructure Company Limited vs The Income Tax Officer CITATION: 2025 TAXSCAN (ITAT) 792

The Income Tax Appellate Tribunal (ITAT) Ahmedabad has directed rectification after finding that depreciation was wrongly considered as net profit in the intimation issued under Section 143(1) of the Income Tax Act for the Assessment Year 2017–18. The appellant, Gujarat State Aviation Infrastructure Company Limited, challenged the order passed by the Commissioner of Income Tax (Appeal)-National Faceless Appeal Centre, Delhi. The assessee argued that the net profit of Rs.1,44,77,479 (1.44 crore) was mistakenly taken instead of the nil profit reflected in the books of accounts, as per item 45 of Part A of the Profit and Loss Statement in the ITR Form-6.

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AO Provided Only 6 Days to Reply to Notice Instead of Mandatory 7 u/s 148A(b): ITAT Quashes Reassessment

Satish Kumar Agrawalvs The Income Tax Officer CITATION: 2025 TAXSCAN (ITAT) 796

The Raipur Bench of the Income Tax Appellate Tribunal (ITAT) quashed the reassessment proceedings due to the Assessing Officer (AO) violating the mandatory statutory timeline prescribed under Section 148A(b) by allowing only six days instead of the minimum required seven for filing a reply. Satish Kumar Agrawal, the assessee, filed his return of income for Assessment Year 2018–19, declaring a total income of Rs. 11,42,800. The case was reopened based on information gathered during survey operations conducted in the cases of Pratyush Steels and M/s Abhishek Enterprises.

ITAT Partly Sets Aside Order u/s 263 for Improper Mandatory Direction to Add Accommodation Entries

Sunil PoonamchandSaraf vs The Principal Commissioner of Income Tax CITATION: 2025 TAXSCAN (ITAT) 791

The Income Tax Appellate Tribunal ( ITAT ) Ahmedabad has partly set aside an order passed under Section 263 of the Income Tax Act, 1961, where the Principal Commissioner of Income Tax ( PCIT ) improperly directed mandatory addition of accommodation entries without due verification. The appellant, Sunil Poonamchand Saraf, had filed an appeal against the order passed by the PCIT, Ahmedabad-1 for the Assessment Year 2013-14. The appellant had originally filed his return declaring an income of Rs.1,99,610, which was accepted in an assessment under Section 147 read with Section 144B. Subsequently, the PCIT observed that the assessee was identified as an end beneficiary of accommodation entries amounting to Rs.4,07,97,829 (Rs. 4.07 crore) from Dishman Group. Finding that no addition was made during reassessment despite recorded reasons and evidence from search and seizure action, the PCIT issued a notice under Section 263, setting aside the assessment and directing the Assessing Officer to make an addition of the alleged accommodation entries.

Assessment Order Served via Email Landed in Spam Folder: ITAT Condones 191-Day Delay in Filing Appeal

Sarika Dadaso Zende vsITO CITATION: 2025 TAXSCAN (ITAT) 797

The Pune Bench of the Income Tax Appellate Tribunal (ITAT) condoned a delay of 191 days in filing the appeal before the Commissioner of Income Tax (Appeals) [CIT(A)] after noting that the assessment order had been served via email and had landed in the assessee’s spam folder, resulting in the delay. Sarika Dadaso Zende, the assessee, is engaged in the business of providing manpower services and trading in housekeeping materials. She filed her return of income declaring Rs. 39.96 lakhs and later revised it to Rs. 15.70 lakhs for the Assessment Year 2020–21. The return was selected for scrutiny, and during assessment, the assessee claimed a deduction for service tax and interest totaling Rs. 26.32 lakhs under Section 43B of the Income Tax Act, 1961.

Steel Scrap or Tax Trap? ITAT Slams PCIT’s Overreach in Ahmedabad Bizman’s Case

Vivaa Tradecom Pvt.Ltd. vs Principal Commissioner of Income-tax-4 CITATION: 2025 TAXSCAN (ITAT) 804

The Income Tax Appellate Tribunal (ITAT), Ahmedabad, overturned a revision order by the Principal Commissioner of Income Tax (PCIT) against Vivaa Tradecom Pvt. Ltd., ruling that the tax authority overstepped its powers under Section 263 of the Income Tax Act, 1961. The case involved alleged bogus transactions in steel scrap trading during the 2015-16 assessment year. Vivaa Tradecom Pvt. Ltd., an Ahmedabad-based company, had declared a loss of Rs.89.92 lakh in its original return. The Assessing Officer (AO) disallowed Rs.3.47 lakh of claimed losses on steel scrap sales to Yug Tradelink Pvt. Ltd., citing an investigation report that questioned the buyer’s genuineness. However, the PCIT later deemed the AO’s inquiry inadequate and directed a re-examination of all purchase and sales entries, potentially treating them as unexplained cash credits.

ITAT Sets Aside CIT(A) Direction on TDS Recalculation, Says Original Demand Already Nullified

Emaar India Limited vsDCIT CITATION: 2025 TAXSCAN (ITAT) 803

The Income Tax Appellate Tribunal ( ITAT ) Delhi Bench has set aside an order by the Commissioner of Income Tax (Appeals) [CIT(A)] that directed the Assessing Officer (AO) to recalculate the Tax Deducted at Source (TDS) demand under Section 194C of the Income Tax Act, 1961. The ITAT ruled that the original demand had already been nullified by the Delhi High Court, making the CIT(A)’s directions untenable. The case involved Emaar India Limited, which had appealed against an order passed by the AO under Sections 201(1) and 201(1A) of the Income Tax Act. The AO had treated the company as an “assessee in default” for not deducting TDS under Section 194A on payments made as External Development Charges (EDC) to the Director of Town and Country Planning (DTCP) through the Haryana Urban Development Authority (HUDA). The demand raised was Rs. 25,09,55,212, including interest. Emaar India challenged this order before both the CIT(A) and the Delhi High Court.

Cera Sanitaryware wins on Section 14A issue; improper invocation of Rule 8D leads to deletion of Rs.4.70 lakh disallowance

Cera Sanitaryware Ltdvs The DCIT CITATION: 2025 TAXSCAN (ITAT) 802

The Income Tax Appellate Tribunal (ITAT) Ahmedabad Bench has ruled in favor of Cera Sanitaryware Limited, deleting a disallowance of Rs.4,70,331 made under Section 14A of the Income Tax Act, 1961, read with Rule 8D of the Income Tax Rules, 1962. The tribunal held that the Assessing Officer (AO) improperly invoked Rule 8D without recording valid dissatisfaction with the assessee’s suo moto disallowance of expenses related to exempt income. Cera Sanitaryware had earned exempt income of Rs.22,44,171 during the assessment year 2020-21 and voluntarily disallowed Rs.3,69,059 as expenses attributable to such income. The AO, however, rejected this computation and applied Rule 8D, calculating a higher disallowance of Rs.8,39,390. After adjusting for the assessee’s suo moto disallowance, an additional Rs.4,70,331 was added to taxable income. The Commissioner of Income Tax (Appeals) [CIT(A)] upheld the AO’s decision, prompting the company to appeal before the ITAT.

Reassessment Without Proper Consideration of Evidence: ITAT Restores Rs.15.88 Lakh Addition for Fresh Verification

Amit Hasmukhbhai Shahvs Income Tax Officer CITATION: 2025 TAXSCAN (ITAT) 800

The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) restored a reassessment case to the Assessing Officer (AO) observing that the AO failed to properly consider the documentary evidence furnished by the assessee in relation to cash deposits amounting to Rs. 15.88 lakh. Amit Hasmukhbhai Shah (assessee), whose case was reopened due to the cash deposit of Rs. 15.88 lakh. The AO sought the assessee to explain the source of cash deposit. The assessee replied that the deposit was made from the loan from farmers, friends and relatives.

VAT Liability Not Disallowable u/s 43B If Not Claimed As Deduction In Profit & Loss Account: ITAT

Dy. Commissioner ofIncome Tax-1(1) vs Grand Motors CITATION: 2025 TAXSCAN (ITAT) 801

In a significant ruling, the Raipur Bench of the Income Tax Appellate Tribunal (ITAT) has held that unpaid VAT liability cannot be disallowed under Section 43B of the Income Tax Act, 1961 if it has not been claimed as a deduction in the profit and loss account. The decision was rendered in the appeal filed by the Dy. Commissioner of Income Tax-1(1), Raipur against Grand Motors, Raipur, for the Assessment Year 2017-18.

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ITAT Quashes Tax Assessment Against Non-Existent Entity, Cites Invalid Jurisdiction

Man Diesel and TurboIndia vs The ACIT CITATION: 2025 TAXSCAN (ITAT) 805

The Income Tax Appellate Tribunal ( ITAT ), Ahmedabad, has nullified a tax assessment order framed against Man Diesel and Turbo India Pvt. Ltd. (formerly Man Turbo India Pvt. Ltd.), ruling that the assessment was invalid as it targeted a non-existent entity due to a corporate amalgamation. The bench quashed the proceedings, citing the Supreme Court’s precedent in PCIT vs. Maruti Suzuki India Ltd. (2019). Man Diesel and Turbo India Pvt. Ltd., the successor entity of Man Turbo India Pvt. Ltd. (MTIPL), challenged the assessment order for AY 2013–14, arguing that the Assessing Officer (AO) had issued notices and framed the assessment in the name of MTIPL despite being informed of its amalgamation effective January 1, 2013. The company had formally notified the AO of the merger on June 24, 2014, yet the AO proceeded with scrutiny in MTIPL’s name, culminating in an order dated November 9, 2016.

Presence of Incriminating Material on Record: ITAT Upholds Income Tax Proceedings U/s 153A

Suryavanshi VenturaPvt. Ltd vs ACIT CITATION: 2025 TAXSCAN (ITAT) 807

The New Delhi bench of the Income Tax Appellate Tribunal ( ITAT ) has upheld the initiation of income tax proceedings u/s 153A of the Income Tax Act, 1961 in view of presence of incriminating material and information on record.

Search had taken place in the premises of the assessee on 22.01.2018 pursuant to which certain incriminating materials were seized and a notice u/s 153A was issued to the assessee. The assessee challenged the issuance of the said notice on the reasoning that no incriminating material was seized from the assessee’s premises and therefore initiation of proceedings u/s 153A was not valid in the eyes of law.

No Income Tax Assessment Beyond 10-year limit u/s153A: ITAT favours Assessee

Suryavanshi VenturaPvt. Ltd vs ACIT CITATION: 2025 TAXSCAN (ITAT) 807

The New Delhi bench of Income Tax Appellate Tribunal (ITAT) has recently quashed an assessment order passed by the Assessing Officer holding that the assessment year was beyond the ten-year outer ceiling limit prescribed by Section 153A of the Income Tax Act,1961. The assessee challenged the assumption of jurisdiction by the Assessing Officer and consequent passing of the Assessment Order. Counsels appearing for the assessee, Ved Jain, Aman Garg and Ishika Dua, challenged the issuance of notice u/s 153A of the Act,1961 for the assessment year 2008-09 on the reasoning that the said notice was issued beyond the period of limitation. Hence, it was contended that the same was illegal and invalid in the eyes of law.

AO Estimates Profit without Rejecting Books, Relies on Faulty Comparison with Sister Concern: ITAT deletes ₹5.82 Crore Addition

ITO vs Ambience Developments CITATION: 2025 TAXSCAN (ITAT) 810

The Pune Bench of the Income Tax Appellate Tribunal (ITAT) deleted the addition of Rs. 5.82 crore, holding that the Assessing Officer (AO) failed to reject the developer’s books of accounts and relied on improper comparisons with a sister concern. Ambience Developments, the assessee, a partnership firm engaged in real estate development, had declared nil income for the Assessment Year 2013-14. The project in question, named ‘Ambience Greendale’, was under scrutiny where the AO questioned the low profitability declared by the firm compared to another project, ‘Ambience Antilla’, carried out by its sister concern.

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