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Showing 201 to 220 of 433132 Records
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2025 (6) TMI 235
Reopening of assessment u/s 147 - society is not eligible for exemption u/s 10(23)(C)(iiiad) and society is showing excess of income over expenditure which is more than maximum amount not chargeable to tax - HELD THAT:- We find that similar and identical issues are decided by the Coordinate Bench of the Tribunal [2025 (2) TMI 1190 - ITAT DELHI] in assessee’s own case wherein the appeal is decided in favour of the assessee as held no merit in the Revenue stand as it has come on record that at the time of framing assessment herein dated 10.09.2021, the assessee had very well succeeded in getting Section 12AA registration. We thus quote section 12A 2nd proviso to hold that benefit of such a registration could not be denied as the reassessment had been granted as on the date of re-assessed.
Thus, we direct the AO to frame the assessment afresh as per the direction given by the Tribunal in assessee’s own case for AY 2017-18 after providing an opportunity of being heard to the assessee. Assessee appeal allowed for statistical purposes.
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2025 (6) TMI 234
Denying grant of registration u/s. 12A - incorrect clause [clause (ii) of S.12A(1)(ac) instead of clause (iii)] while filing Form 10AB - HELD THAT:- We note that similar issue came up for consideration before in the case of Kimaya Ashram Charitable Trust [2025 (1) TMI 1049 - ITAT PUNE] set aside the matter to the file of the Ld. CIT(E) with a direction to decide the issue afresh wherein as following the case of Vir Sewa Mandir [2024 (9) TMI 1510 - ITAT DELHI] we find force in the arguments of Ld. Counsel of the assessee and accordingly deem it appropriate to set-aside the order passed by Ld. CIT, Exemption, Pune and remand the matter back to him with a direction to decide the issue afresh after treating the original application as filed by the assessee under correct/desired section i.e. section 12A(1)(ac)(iii) of the IT Act. The assessee is also hereby directed to respond to the notices issued by Ld. CIT, Exemption, Pune in this regard and produce specific documents/evidences desired by Ld. CIT, Exemption, Pune in support of application for registration u/s 12A.
In our humble view, wrong selection of section code/clause would not disentitle the assessee to its rightful claim and cannot be treated as fatal to the proceedings initiated after the filing of the application. Hence, the Ld. CIT(E) ought to have given an opportunity to the assessee to rectify the defect. We, therefore, set aside the impugned order of the Ld. CIT(E) who shall give an opportunity to the assessee to file the correct application - Appeal of the appellant is allowed for statistical purposes.
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2025 (6) TMI 233
Reopening of assessment u/s 147 - Addition u/s 68 - Penny Stock Transaction - AO was in position of tangible information basis investigation carried out by the Investigation wing that the assessee has transacted in shares of penny stock company - HELD THAT:- There is clear non-application of mind by the AO as the AO has failed to establish the necessary nexus between the information so received and formation of belief as to how the income has escaped assessment in the hands of the assessee. The assessee has neither claimed exemption u/s 10(38) nor claimed short term capital loss in her return of income and in such a situation, how the information so received can form the basis for formation of belief that income has escaped assessment is not discernable from the reasons so recorded by the AO.
Even though the proviso to section 147 is not strictly applicable, where the AO has alleged in the reason so recorded that income has escaped assessment due to failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment, the AO has failed to spelt out what material facts have not been disclosed by the assessee in the reasons so recorded.
Merely stating that there is a failure without specifying the nature and extent of failure in order to constitute material fact is not sufficient for assumption of jurisdiction u/s 147 of the Act.
It is a settled legal proposition that the AO has to speak through the reasons and reasons alone and in absence of any reasoning apparent from the reasons so recorded as to how he has analysed the information so received and come to a prima facie belief that income has escaped assessment, the assumption of jurisdiction u/s 147 clearly suffers from jurisdictional defect and the same cannot be sustained and is hereby set-aside. Appeal of the assessee is allowed.
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2025 (6) TMI 232
Denial of benefit of section 11 - order passed u/s 143(1) which raised demand without granting exemption u/s 11 when the assessee did not claim such exemption in the return of income - HELD THAT:- It is apparent from the order u/s 143(1) that assessee had not claimed any exemption u/s 11 of the Act in the return of income. Since assessee had not claimed any exemption u/s 11 of the Act, in the return of income, the DCIT(CPC) while passing the order u/s 143(1) has not granted any exemption. In this scenario, we do not find any fault with the order of the DCIT(CPC) as the order of the DCIT(CPC) is based on return filed by the assessee. In the statement of facts filed before this Tribunal, the assessee has claimed that it has ironically filed return of income in Form No.5 whereas the form applicable for trust was Form No.7. If this is the fact assessee should have had filed a revised return after getting his PAN number corrected. However, assessee had not taken any action almost for seven and half years. The grounds raised by the assessee are dismissed.
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2025 (6) TMI 231
Rejection of approval u/s. 80G(5) - assessee had claimed expenses on a “Bhagwat Katha” event, which constituted 36.87% of total receipts - CIT(E) was of the view that this expenditure clearly exceeded the permissible limit and appeared to be of a religious nature, thereby violating Section 80G(5B) - HELD THAT:- Assessee placed reliance on various judicial precedents on the proposition that expenditure incurred on supporting prayer halls at places of worship, which are open to the public at large are not expenses of a “religious nature”. Accordingly, in the interest of justice, the matter is restored to the file of Ld. CIT(E) for de-novo consideration and the assessee / applicant trust would be at liberty to place judicial precedents on the subject in support of it’s case.
Appeal of the assessee / applicant trust is allowed for statistical purposes.
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2025 (6) TMI 230
Maturity proceeds receipts from Max Life Insurance ULIP plan - whether exempt u/s.10(10D) OR chargeable under the head “Income from other sources” - HELD THAT:- Contention that the sale of ULIP as capital gains raised by the assessee was not examined by the Lower Authorities specially with reference to the decision rendered in the case of Mihir K. Jhaveri [2023 (8) TMI 276 - ITAT MUMBAI] which considered the amendment to Section 2(14)(c) of the Act. Therefore in the interest of justice, we deem it fit to set-aside the matter back to the file of Jurisdictional Assessing Officer to consider the issue afresh and pass orders in accordance with law by providing opportunity of hearing to the assessee. Appeal filed by the Assessee is allowed for statistical purpose.
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2025 (6) TMI 229
Addition u/s 68 - accommodation entry receipt - HELD THAT:- AO has not made any independent inquiry about the sale transaction by summoning the Notary Public who Notarised/Signed the Sale Agreement or Cancellation Deed, but simply concluded that the Agreement is unregistered.
AO is also not clear whether it is compulsory to Register the Sale Agreement under the Registration Act, during March 2018. Whereas the assessee has discharged its initial onus cast upon it by providing all the relevant materials before the AO. Further when the AO issued summons u/s.133[6] to M/s. VRR Financial, the same was replied and furnished the relevant documents. Therefore the identity and genuineness are proved and the question of invoking section 68 of the Act does not arise in this case.
Nature of Transaction - The assessee has produced substantial documentation to establish that the amount of ₹3.5 crore was advance against property transaction, not a loan. The Agreement to Sale and Deed of Cancellation are consistent with the timeline and supported by ledger entries and confirmations. The property in question, though not shown in the Schedule AL-1, has been explained through their CA certificate and supporting ownership documents which was not disputed by AO on merits.
Genuineness and Identity of Party - The creditor is an income tax assessee with PAN, filed ITRs and audit reports are available. The transaction were carried out through banking channels and repayment has been made, including compensation for cancellation deed. Further reply to the summons u/s. 133[6] by M/s. VRR Financial makes it clear the identity and genuineness of the transaction and not on accommodation entry.
As in the case of Ambe Tradecorp Pvt Ltd. [2022 (7) TMI 902 - GUJARAT HIGH COURT] held that where assessee took loan from two parties and assessee had furnished requisite material showing identity of lenders and that assessee was not beneficiary, as loan was repaid in subsequent year, no addition u/s.68 could be made on account of such loan.
As assessee has fully discharged its onus cast upon it under section 68, whereas the AO has failed to conclusively rebut the evidences and made addition based on presumption and not by conclusive evidence which is not sustainable in law. Appeal filed by the Revenue is hereby dismissed.
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2025 (6) TMI 228
Rejecting the application for approval u/s. 80G(5)(iv)(B) - bona fide error in selecting sub- clause (iv) instead of sub-clause (ii) of section 80G(5) of the Act - HELD THAT:- It would be useful to reproduce the relevant extracts of the decision of Rotary Charity trust [2025 (2) TMI 114 - ITAT MUMBAI] there is merit in claim of the ld. AR that assessee has selected the wrong section code inadvertently while filing the application for final registration in Form 10AB.
We notice that assessee did not have the opportunity of being heard before ld. CIT(E) due to incorrect course of action advised, which otherwise assessee might have explained the facts to avoid the impugned rejection. In view of these discussions and respectfully following the above decision of North Eastern Social Research Centre [2024 (7) TMI 890 - ITAT KOLKATA] we remit the issue back to the file of ld. CIT(E), with a direction to grant final approval to assessee under Clause (iii) to first proviso to section 80G(5) of the Act, if assessee is otherwise found eligible.
Appeal of the assessee is allowed for statistical purposes.
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2025 (6) TMI 227
Denial of claim u/s 54 and 54F - purchase of multiple floors/flats/units in the same building being part of one house OR multiplex house consisting of multiple floors/flats/units in the same building - HELD THAT:- As decided in the case of D. Ananda Basappa [2008 (10) TMI 99 - KARNATAKA HIGH COURT] as well, has held “that the expression “a residential house” in section 54(1) of the Act has to be understood in a sense that building should be of residential nature and “a” should not be understood to indicate a singular number and where an Assessee had purchased two residential flats, he is entitled to exemption u/s 54 in respect of capital gains on sale of its property on purchase of both the flats situated side by side and purchased by separate sale deeds”.
Admittedly, the provisions of section 54 of the Act are beneficial provisions for the benefits of the Assessee’s and therefore the same are requires to be construed liberally and thus liability cannot be fastened on the Assessee, to prove its case by strict proof. And therefore simply on the reason that the Assessee has not shown the sanctioned plan as claimed by the Ld. DR and therefore the Judgment of Raman Kumar Suri [2012 (12) TMI 421 - BOMBAY HIGH COURT] is not applicable to the instant case, is not enough to disallow the bonafide claim of the Assessee, which has otherwise duly been established by the Assessee by producing relevant documents and in view of various judgments referred to above, relevant to the issue as involved in the case.
Thus, claim of the Assessee as claimed being exempt u/s 54F of the Act, is liable to be allowed. Thus, the same is allowed.
Claim being indexed cost of improvement - Both the parties have submitted that as the AO has already allowed the total amount as claimed on account of capital gain, being exempt u/s 54 and therefore denial being indexed cost of improvement, in effect, has no consequence and therefore we are inclined not to go into the controversy with regard to such claim as adjudication of the same would prove to be futile exercise. Thus, the same is left un-adjudicated.
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2025 (6) TMI 226
Reduction of exemption claimed U/sec 10AA - whether AO erred in calculating the exemption amount U/sec 10AA based on original ratio as against the revised ratio after adjustment to profit of the SEZ unit? - HELD THAT:- From the perusal of the assessment order it is seen that ld. AO has removed the sales incurred on the sales to other SEZ units, however, he has not reduced the corresponding cost. In other words, when ld. AO has taken the sales of Rs. 42,83,757/- not covered under the export sales, then corresponding cost of Rs. 34,15,260/- which is derived at the cost of sales of SEZ units should have been reduced.
We agree with the contention of the ld. Counsel for the assessee and direct the ld. AO to verify the figures and allow the additional amount of exemption as per the working given above. With this direction, appeal of the assessee is allowed.
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2025 (6) TMI 225
Compensation received for termination of assessee’s employment - "profits in lieu of salary" taxable u/s 17(3)(i) or is a capital receipt exempt from tax - assessee submitted that the said amount received from the Company is in the nature of capital receipt and the same is paid voluntarily and as compensation on premature termination of employment.
HELD THAT:- We have perused the order of Shrikant Anantrao Zori [2025 (1) TMI 1537 - ITAT PUNE] and find that the Tribunal in turn relying on various other decisions of the Coordinated Bench(es) of the Tribunal including the decision of Mahadev Vasant Dhangekar [2023 (4) TMI 569 - ITAT PUNE] has decided the impugned issue in favour of the assessee under the similar set of facts and held the payment of ex-gratia compensation received by the assessee was voluntary in nature without there being any obligation on the part of the employer to pay further amounts to the assessee in terms of any service rule and therefore, would not amount to compensation in terms of section 17(3) of the Act. We, therefore, set aside the order of the CIT(A) / NFAC and direct the Assessing Officer to delete the addition. The grounds raised by the assessee are accordingly allowed.
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2025 (6) TMI 224
Denial of benefit of deduction u/s. 80JJAA - Form 10DA is not filed within the due date specified in the Act i.e. one month before the due date of filing of return of income on 30-09-2023 - HELD THAT:- The claim of the assessee for deduction u/s. 80JJAA of the Act cannot be denied only for the reason that the assessee has uploaded Form 10DA after the due date prior to 30 days from the filing of the return of income.
The assessee has filed the Form along with the filing of return of income. Thus, it is mere lapse on part of the assessee on the procedural aspects, the assessee cannot be denied the claim of deduction which the assessee is entitled if he would have filed Form 10DA within the stipulated time. Hence, the appeal of the assessee is allowed.
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2025 (6) TMI 223
Validity of Reopening of assessment - reasons recorded for reopening not signed by the AO for validation - cash deposits in the bank account unexplained - HELD THAT:- At the time of hearing, DR produced the documents related to the complete copy of reasons recorded for reopening the assessment as well as the copy of the approval accorded by the concerned authorities u/s 151 of the Income Tax Act, 1961 during the course of hearing. The order-sheet details were submitted for approval as noted in the order-sheet attached to the said documents. It is pertinent to note that the reasons were duly signed by the Assessing Officer and the show cause notice dated 11.10.2018 was signed digitally by the same Assessing Officer and the timing for the same is mentioned at the bottom of the said document/show cause notice itself. Thus, the contentions of the Ld. AR does not sustain as the relevant reasons and the subsequent show cause notice and statutory notices were rightly signed digitally by the AO. Thus Assessment order is valid and there is no need to interfere with the findings of the CIT(A).
Addition u/s 68 - AO after receiving the details from the assessee has verified the amount and has taken into account the entire cash deposit in the bank account. The contention of the AR that the AO has not demanded anything to prove genuineness of cash credit u/s 68 is not justified once, the assessee was asked to give the source of the deposits as mentioned in Notice u/s 142(1). Therefore, this contention is also rejected.
TDS is not deducted for labour payment is not valid ground because for every labour payment provisions of Section 194C are not applicable. This contention of the Ld. AR required the details upon which the assessee can prove that Section 194C will not be applicable for the payment below the threshold limits as prescribed under Income Tax Act which the assessee failed to prove. Therefore, CIT(A) was right in dismissing the appeal of the assessee.
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2025 (6) TMI 222
Revision u/s 263 - exemption of LTCG u/s 10(38) on shares received pursuant to amalgamation - allegation against the assessee is that he has made investment in the shares of a paper company who was amalgamated with another paper company and on sale of those shares, he has earned bogus Long Term Capital Gain - HELD THAT:- It is pertinent to note that alleged four companies discussed in the reasons for re-opening by the AO have amalgamated in M/s Twenty First Century India Ltd. The assessee was investor of M/s Sarathi Dealers Pvt. Ltd. which is one of the amalgamated company.
Once companies have been amalgamated under the order of the Hon'ble High Court, this would show that those companies were in existence. The shares have been transferred to D-mat account of the assessee which have been later on sold. All these aspects have been considered by the AO and he has also accepted.
PCIT was of the view that assessee should be confronted with the statement given by Shri Ashok Kumar Kayam, Proprietor of M/s Ashok Kumar Kayam. It is pertinent to note that this statement was not recorded in the presence of the assessee. It was from the back of the assessee by DDIT (Investigation) Kolkata in some other proceedings. How this statement has a relevancy unless some other corroborated evidence is being collected by the Investigation Wing, Kolkata.
The alleged report was even not supplied to the assessee. It was just an information for setting the machinery in motion for taking enquiries against the assessee. The said report can never be termed as a gospel truth which can be given preference over to the judgement of Kolkata High Court approving the amalgamation.
If the test propounded in the order of Mrs. Khatiza S. Oomerbhoy [2006 (2) TMI 201 - ITAT BOMBAY-H] are applied in the present case, then it would come out that every error is not required to be corrected u/s 263.
AO is also a quash judicial officer who has taken one of the view possible on the given set of facts. The CIT has not pointed out as to how his view was absurd and against the law. Therefore, no 263 is tenable - Decided in favour of assessee.
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2025 (6) TMI 221
Addition u/s 68 - unsecured loans treated as unexplained cash credits - onus to prove - assessee submits that assessee furnished bank statement of the lender and before CIT(A) explained that lender has received the repayment of loan given in earlier financial year - HELD THAT:- The revenue, apart from issuing notices under section 131 at the instance of the assessee, did not pursue the matter further. The revenue did not examine the source of income of the said alleged creditors to find out whether they were credit-worthy or were such who could advance the alleged loans.
There was no effort made to pursue the so-called alleged creditors. In those circumstances, the assessee could not do any further. In the premises, if the Tribunal came to the conclusion that the assessee had discharged the burden that lay on him, then it could not be said that such a conclusion was unreasonable or perverse or based on no evidence.
Thus, once the assessee has discharged his primary onus in proving identity, creditworthiness and genuineness of transaction, the assessing officer was not justified in making addition in absence of any evidence on record for making addition under section 68. Thus, the addition u/s 68 is deleted. Hence, the grounds of appeal raised by the assessee are allowed.
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2025 (6) TMI 220
Re-assessment proceedings u/s 147 beyond period of limitation - procedural requirements u/s 148A - scope of period prescribed under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (“the TOLA”) - HELD THAT:- It is evident that the Hon’ble Courts, consistently considering the submissions made by the Revenue before the Hon’ble Supreme Court in Rajeev Bansal [2024 (10) TMI 264 - SUPREME COURT (LB)],have held that the re-assessment notice issued under section 148 of the Act for the assessment year 2015-16 is barred by limitation. Thus, on this limited basis alone, the notice dated 29/07/2022, issued under section 148 of the Act in the present case, is liable to be quashed, being time-barred under the provisions of the Act. We order accordingly. Consequently, the entire re-assessment proceedings and final assessment order passed u/s 147 read with section 144C(13) read with section 144B of the Act are also quashed. Assessee appeal allowed.
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2025 (6) TMI 219
Assessment of trust - Addition u/s 68 - treating donation received from trustee as unexplained cash credit - HELD THAT:- We find that assessee has furnished various documents in the paper book explaining the genuineness of the said donation.
Once the donor has given the confirmation and also accepted to have given donation to the assessee along with the source of income, burden of proof stands discharged by the assessee and the same shifts on to the Revenue. In case Revenue was not satisfied with the confirmation and statement given by Dr. Bhagwan Nivrutti Elmane, then they should have taken action against the alleged donor for giving false statement. However, in absence of any such action on the part of Revenue, we find that assessee has successfully explained the nature and source of the alleged donation received from Dr. Bhagwan Nivrutti Elmane during the year and the same cannot be taxed u/s. 68.
Cash donation received from Mr. Bhagwan Dnyanoba - This donation has also been received in cash. Apart from confirmation letter of Mr. Bhagwan Dnyanoba, there is no other document to justify the source of income. In this case, no statement was taken by the AO. It is also observed that the amount received as donation during the year has been applied for charitable purposes and the same is not in dispute at the end of Revenue authorities. Income-tax return along with Audit Report of the assessee society has been filed. Now once the assessee is unable to prove the detail of alleged donation, section 115BBC of the Act can be invoked which is regarding anonymous donation to be taxed in certain cases.
Subsection (1)(i)(B) of section 115BBC applies on the given facts of the case as the donation received has been applied for charitable purposes but since it is held to be anonymous donation, only the amount in excess of Rs. 1.00 lakh can be taxed @30%. We therefore are of the considered view that out of Rs. 1.10 lakh only Rs. 10,000/- can be subjected to tax as per the provisions of section 115BBC of the Act as we have treated Rs. 1.10 lakh of cash donation as anonymous donation. Ground No.2 raised by the assessee is partly allowed.
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2025 (6) TMI 218
Denial of exemption u/sec. 11 - assessee society is not registered u/sec.12A - appellant society, which changed its name and obtained a new PAN post the bifurcation of Andhra Pradesh into Telangana - HELD THAT:- After partition of Andhra Pradesh State, the Government of Telangana has approved name change from The Zoo Authority of Andhra Pradesh to The Zoos and Parks Authority of Telangana to continue the conservation of wildlife and environment activities of incumbent Zoo Authority of Andhra Pradesh.
There was no change either in objects of the assessee society or activities. Further, only there was a change in name. After change in name, the assessee society has not applied for registration u/sec. 12A of the Act. In absence of registration u/sec. 12A, the assessee society has claimed exemption u/sec. 11 of the Act in respect of it’s total income.
AO -CPC, Bengaluru has processed the return u/sec. 143(1) of the Act and rejected the exemption u/sec. 11 of the Act on the ground that assessee society is not registered u/sec. 12A of the Act.
Once the society is not registered u/sec. 12A of the Act, then, the said society/trust cannot claim the benefit of exemptions u/sec. 11 and 12 of the Act. Therefore, we are of the considered view that, there is no error in the order of the Assessing Officer/CIT(E) in rejecting the benefit of exemption u/sec. 11 of the Act to the assessee society for all assessment years. Thus, we upheld the rejection of exemption u/sec. 11 of the Act.
Assessment of income of the assessee society - AO having rejected the exemption u/sec.11 has considered gross receipts of the assessee society for the purpose of taxation - HELD THAT:- It is well settled principle of law that, once the income of any Trust/Institution or Society is considered as AOP and assessed under normal provisions of the Act, then, all permissible deductions including expenditure incurred out of said income should be allowed as deduction. This view is supported by the decision of Kingston Educational Trust 2019 (11) TMI 1839 - ITAT CHENNAI] wherein held that, only net income needs to be taxed.
AO and the learned CIT(A) are erred in taxing gross receipts of the assessee society instead of net income as per the financial statements. However, fact remains that since the assessment order is u/sec. 143(1), the Assessing Officer does not have an occasion to verify the correctness of various expenditure claimed by the assessee. Therefore, in our considered view, the matter needs to go back to the file of Assessing Officer for further verification. Thus, we set aside the orders of the learned CIT(A) and restore the issue back to the file of Assessing Officer for reconsideration of the issue.
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2025 (6) TMI 217
Disallowance u/s 37(1) - AO found that the assessee has booked management fees only as revenue from operations disallowed u/s 37(1) as revenue expenditure and why it should not be capitalized for amortization in subsequent assessment years - AO was of the opinion that the assessee has not followed the matching principles of accounting which requires that the expenses incurred during the period be recorded in the same period in which the related revenue are earned - CIT(A) deleted addition.
HELD THAT:- We have to say that the expenses have to be incurred for the purposes of the business and not for earning profit. Therefore, the allegation of the AO that the revenue of the assessee does not match with the expenditure incurred does not hold any water. All that has to be seen is that whether the expenses have been incurred for the purpose of business and whether expenses are of revenue in nature. If the answer to both is yes, the same has to be allowed irrespective of the quantum of revenue. We find that that the ld. CIT(A) has discussed each and every aspect of the expenditure incurred and has given a categorical finding of fact which are not disputed by the revenue. Therefore, we do not find any reason to interfere with the findings of the ld. CIT(A). Appeal of the revenue is dismissed.
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2025 (6) TMI 216
Penalty levied u/s 271(1)(b) - notices issued u/s 142(1) were not properly served on the assessee - HELD THAT:- Admittedly, the penalty was levied due to noncompliance with notices issued u/s 142(1). Assessee has filed before the CIT(A) sufficient material evidencing that the notices were returned unserved with remarks such as “house locked” and “gone to Canada.” The assessee also produced a copy of his Canadian passport to substantiate his claim of being abroad during the relevant time.
In our considered view, the explanation offered by the assessee, along with postal remarks and proof of foreign residency, merited deeper appreciation. The penalty u/s 271(1)(b) is quasi-criminal in nature and cannot be sustained merely on technical non-compliance, particularly where service of notice itself is in dispute and the conduct of the assessee does not reflect contumacious defiance.
We further find that the CIT(A), while affirming the penalty, did not properly deal with the evidence of returned notices or the relevance of judicial precedents cited by the assessee, including the decision of Smt. Rekha Rani [2015 (5) TMI 1100 - ITAT DELHI] which held that failure to respond to unserved notices should not automatically result in penalty under Section 271(1)(b).
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