ITAT Mumbai holds that interest on borrowings used to acquire controlling interest in a foreign subsidiary engaged in the same business is allowable under Section 36(1)(iii) as business expenditure.
ITAT Chandigarh holds that re-opening under Section 147 requires more than portal data; AO must possess concrete material to form belief of escaped income.
ITAT Bangalore holds that Section 263 cannot be invoked merely because the Commissioner disagrees with a plausible view taken by the AO on interest income eligibility under Section 80P.
ITAT holds that TDS under Sections 194C and 194J does not arise if aggregate payments fall below statutory thresholds or exemption conditions are met, clarifying compliance obligations for traders.
ITAT Delhi holds that under Section 153A, the Rs.50 lakh threshold for extended assessment applies to cumulative undisclosed income, not per assessment year, clarifying jurisdictional limits.
ITAT Chennai holds that credit card debits cannot be taxed as unexplained cash credits under Section 68; assessment must focus on factual verification within limited scrutiny scope.
ITAT holds that reopening under Section 147 requires tangible material linking income escapement to the assessment year; mere information from investigation wing is insufficient.
ITAT Chennai holds that a trust qualifies for exemption under Section 56(2)(x) if established solely for relatives, even if deed permits removal but not addition of non-relatives.