Indian Income Tax Appellate Tribunal rulings

The Income Tax Appellate Tribunal (ITAT) in India has issued several rulings addressing diverse tax disputes, deductions, and assessment procedures across multiple jurisdictions. In early August, the Bangalore bench denied a Section 80P deduction claim for a Primary Agricultural Credit Co‑operative Society due to filing delays, while the Jaipur bench ruled in favor of Bhandari Bros, directing that TDS credit be granted despite being deducted under the wrong provision. By mid-August, the tribunal's activity expanded to include rulings in Hyderabad, New Delhi, Bangalore, Pune, and Delhi. These decisions covered topics such as profit estimation on seized materials, the validity of capital loss claims on unlisted shares, partner remuneration deductions, and transfer pricing adjustments. Additionally, the Delhi ITAT remanded an assessment for Hitachi Astemo Haryana Private Ltd. because the final order failed to follow mandatory directions from the Dispute Resolution Panel. In late August, the tribunal issued further rulings across several cities. In Mumbai, the ITAT upheld tax exemptions for the National Payments Corporation of India (NPCI) under Sections 11 and 12, ruling that transaction fees for services like RuPay and IMPS do not render its operations commercial. In Delhi, the tribunal ruled in favor of K R Pulp & Papers Ltd., deleting adjustments exceeding ₹84 crore regarding electricity and steam transfers. Other recent decisions include the Mumbai ITAT directing TDS payment verification for Vaayu Infrastructure LLP, the deletion of tax additions for Eager Corporation due to a lack of incriminating material, and the Bangalore ITAT condoning a 247-day delay for a farmer's appeal. Expanding beyond the ITAT, the Supreme Court of India ruled in the case of Wipro Limited that conditions under Section 10B(8) of the Income Tax Act, 1961, regarding the timing of declarations for opting out of certain exemptions, are mandatory.