“profits and gains of business or profession”

Income HeadsSection 28Section 281,710 judgments

THE KARNATAKA STATE COOPERATIVE AGRICULTURE AND DEVELOPMENT BANK LIMITED ,BANGLAORE vs. INCOME TAX OFFICER, WARD-5(2)(1), BENGALURU

In the result the appeal of the assessee is partly allowed for statistical purposes

ITA 1821/BANG/2025[2022-23]Status: DisposedITAT Bangalore09 Apr 2026AY 2022-23

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2022-23

For Appellant: Shri Bhardwaj Sheshadri, Advocate &For Respondent: Shri Subramanian, JCIT (DR)

Section 250Section 56Section 80PSection 80P(2)(a)

Section 80P(2) of the I.T. Act for a Co-operative Society that is assessed to tax under the head of 'Profits and Gains of Business or Profession' is of the whole of the amount of profits and gains of business attributable to any one or more of its activities

STEP LOGISTICS PRIVATE LIMITED,RAIPUR vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE 1(1), RAIPUR, RAIPUR

In the result, appeal of the assessee in ITA

ITA 636/RPR/2025[2017-18]Status: DisposedITAT Raipur19 Mar 2026AY 2017-18

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita No.636/Rpr/2025 "नधा"रण वष" / Assessment Year : 2017-18 Step Logistics Private Limited A-1, Mahavir Gaushala Complex, K.K Road, Raipur (C.G.)-492 001 Pan: Aancs0382F

For Appellant: S/shri Praveen Khandelwal &For Respondent: Dr. Priyanka Patel, Sr. DR

Section 127Section 143(2)Section 143(3)Section 68

Section 29 of the Act prescribes that the income referred to in section 28 which is assessable under the head “Profits and gains of business or profession” shall be computed in accordance with the provisions contained in sections 30 to 43A of the Act. Section 145 of the Act provides

AUTO NIRVAHAKARA CREDIT OPERATIVE SOCIETY LIMITED,UDUPI vs. INCOME TAX OFFICER, WARD-3, UDUPI

In the result, the appeal of assessee is partly allowed for statistical purposes

ITA 2214/BANG/2025[2017-18]Status: DisposedITAT Bangalore17 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri Prasanna Shenoy, CAFor Respondent: Shri Ganesh R Ghale, Advocate – Standing

Section 250Section 28Section 80P(2)(a)

engaged in providing credit facilities to its members. Therefore, once the income of the assessee is assessed under the head “profits and gains of business or profession” arising from the activity of providing credit facilities to its members, the same would qualify for deduction

MR. SHRIDHAR GANGARAM ANUMANDALA ,MUMBAI vs. ITO WARD 22(3)(6), MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 8391/MUM/2025[2020-21]Status: DisposedITAT Mumbai13 Mar 2026AY 2020-21

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI JAGADISH (Accountant Member)

For Appellant: NoneFor Respondent: Shri S. Anbuselvan (Sr. DR)

Section 139(1)Section 143Section 143(3)Section 234ASection 234BSection 250Section 50Section 55ASection 56(2)(x)Section 69

advised.” 4. The assessee filed the return of income under section 139(1) of the Act, declaring income under the head “Profits and Gains of Business or Profession.” The assessment was completed by the Ld. AO under section 143(3) of the Act. During the course of assessment proceedings

APCOTEX INDUSTRIES LIMITED,RAIGARH vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 15(1)(1), AAYAKAR BHAWAN, MUMBAI

In the result the appeal filed by the assesse stands partly allowed

ITA 6023/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Mar 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 143(2)Section 14ASection 35

from House Property”, the claim of depreciation has been made under section 32, which pertains to income assessable under the head “Profits and Gains of Business or Profession.” 7.1. Under the scheme of the Act, the allowability of deductions is determined by the head under which the income is assessed ... only the deductions specifically provided under section 24 are permissible. On the other hand, where income is assessed under the head “Profits and Gains of Business or Profession,” the assessee may claim deductions allowable under that head, including depreciation under section 32. Consequently, the same income stream cannot simultaneously

THE BANK OF TOKYO MITSUBISHI UFJ,NEW DELHI vs. DCIT, CIRCLE- 3(1)(1), INTERNATIONAL TAXATION, NEW DELHI

ITA 7212/DEL/2017[2013-14]Status: DisposedITAT Delhi13 Mar 2026AY 2013-14

Bench: Vikas Awasthy & Shri Brajesh Kumar Singh

Section 143(2)Section 143(3)Section 144Section 144C(5)Section 44C

adjusted total income. It is pertinent to note that although the deduction is allowed under the head “Profits and gains from business or profession” however, the same is computed with reference to the total income computed under the provisions of the Act. clause (i) of Explanation to section 44C provides ... deduction of only Rs.5 (5% of Rs.100) and the balance amount is to be ignored while computing income under the head "Profits and gains from business or profession". In the event, the provisions of section 44C are not applicable, the entire head office expenditure of Rs.10 is allowable

DCIT, CIRCLE-1(1)(1), AHMEDABAD, AHMEDABAD vs. AMNEAL PHARMACEUTICALS PRIVATE LIMITED, AHMEDABAD

In the result, the appeal of the Department is dismissed

ITA 2139/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2022-23

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Dhinal Shah, ARFor Respondent: Shri Dhinal Shah, AR

Section 135Section 37(1)Section 80GSection 80G(5)

further submitted that the disallowance under Explanation 2 to section 37(1) operates only with respect to deduction under the head “profits and gains of business or profession” and does not restrict deduction available under Chapter VI-A of the Act. The assessee also relied upon certain judicial precedents wherein ... section 37(1) of the Act. Therefore, the assessee has not claimed the said expenditure as a deduction under the head “profits and gains of business or profession”. The only claim made by the assessee is a deduction under section 80G of the Act in respect of donations made

UDAYA SOUHARDA CO-OPERATIVE SOCIETY LIMITED ,BANGALORE vs. INCOME TAX OFFICER WARD-5(1)(1), BANGALORE

In the result, the appeal of assessee is hereby allowed for statistical purposes

ITA 2472/BANG/2025[2020-21]Status: DisposedITAT Bangalore12 Mar 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2020-21

For Appellant: Shri Tharun Kothari, CAFor Respondent: Shri Subramanian, JCIT (DR)

Section 57Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

SHRI. SHANTHISAGAR CO OP CREDIT SOCIETY LIMITED,HUBLI vs. INCOME TAX OFFICER, WARD-2(1), HUBLI

In the result, the appeal of the assessee is hereby partly allowed for statistical purposes

ITA 2081/BANG/2025[2017-18]Status: DisposedITAT Bangalore12 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Smt. Harsha J, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing

Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

SREE CAUVERY SOUHARDA CREDIT SAHAKARI SANGHA NIYAMITHA,BENGALURU vs. INCOME TAX OFFICER WARD 1(1)(1), BENGALURU

ITA 1854/BANG/2025[2018-19]Status: DisposedITAT Bangalore12 Mar 2026AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Smt. Sumana, CAFor Respondent: Shri Subramanian, JCIT (DR

Section 10Section 250Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

ASST. COMMISSIONER OF INCOME TAX, MUMBAI vs. RELIANCE RETAIL LIMITED, MUMBAI

In the result, the appeal filed by the Revenue is dismissed, whereas the appeal filed by the assessee is partly allowed

ITA 4244/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Mar 2026AY 2019-20

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 135Section 143(3)Section 144BSection 14ASection 250Section 37(1)Section 80GSection 80JSection 92C

incurred for the purposes of business or profession and therefore cannot be allowed as deduction while computing income under the head “Profits and gains of business or profession.” The said Explanation does not impose any restriction on deductions allowable under other provisions of the Act. Section 80G, on the other

MUMBAI INTERNATIONAL AIRPORT LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(2)(1), MUMBAI, MUMBAI

The appeal of the assessee is allowed for statistical purposes, whereas the appeal of the Revenue is dismissed

ITA 6692/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Mar 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokara.Y:2014-15 Mumbai International Vs. Dcit, Circle – 2(2)(1) Airport Ltd., Aayakar Bhavan, Mk Road 1St Floor, Terminal-1B, New Marine Lines, Mumbai – Chhatrpati Shivaji 400020. International Airport, Santacruz (E), Mumbai – 400099. Pan/Gir No. Aaecm6285C (Applicant) (Respondent) A.Y:2014-15 Dcit, Circle – 2(2)(1) Vs. Mumbai International Aayakar Bhavan, Mk Road Airport Ltd., New Marine Lines, Mumbai – 1St Floor, Terminal-1B, 400020. Chhatrpati Shivaji International Airport, Santacruz (E), Mumbai – 400099. Pan/Gir No. Aaecm6285C (Applicant) (Respondent) Assessee By Shri Saurabha Soparkar Virtually Appeared Revenue By Shri Annavaram Kosuri, Sr. Ar Date Of Hearing 25.02.2026 Date Of Pronouncement 09.03.2026 आदेश / Order Per Makarand V Mahadeokar, Am: These Cross Appeals Are Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals) Under Section 250 Of The Mumbai International Airport Ltd., Mumbai Income-Tax Act, 1961 Dated 05.08.2025 In The Case Of The Assessee For Assessment Year 2014–15. The Assessment In The Present Case Was Originally Completed By The Assessing Officer Under Section 143(3) Of The Act Vide Order Dated 30.12.2017. Since The Issues Involved In The Appeals Of The Revenue As Well As The Assessee Arise Out Of The Same Appellate Order Of The Ld. Cit(A), These Appeals Were Heard Together & Are Being Disposed Of By Way Of This Common Order For The Sake Of Convenience & Brevity.

Section 143(3)Section 14ASection 250Section 28Section 32(1)(ii)Section 35D

purpose of business and the said expenditure was allowed to be deducted in computing the business income chargeable under the head 'Profits and gains of business or profession' under section 37(1). 8.11 I also find force in the argument of the appellant that retrenchment compensation is nothing but lump

VALUELABS LLP,HYDERABAD vs. DCIT., CENTRAL CIRCLE 8(1), HYDERABAD

ITA 1609/HYD/2025[2020-21]Status: DisposedITAT Hyderabad06 Mar 2026AY 2020-21

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी. सं/Ita No.1609/Hyd/2025 (निर्धारण वर्ष/Assessment Year:2020-21) Valuelabs Llp, Hyderabad. Vs. Dcit, Pan: Aakfv2276K Central Circle-8(1), Hyderabad. (Appellant) (Respondent) निर्धारिती द्वारा/Assessee By: Shri P. Murali Mohan, Ca राजस्व द्वारा / Revenue By: Ms. U. Mini Chandran, Cit-Dr सुनवाई की तारीख / Date Of Hearing: 29/01/2026 घोषणा की तारीख / Date Of 06/03/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Firm Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 13/08/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 143(3) R.W.S 144B Of The Income Tax Act, 1961 (For Short, "The Act"), Dated 27/09/2022 For The Assessment Year (Ay) 23/11/2021. The Assessee Firm Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri P. Murali Mohan, CAFor Respondent: Ms. U. Mini Chandran

Section 115BSection 143(3)Section 2(24)(xviii)Section 250Section 80

result or incidence of regular business activity but are entitlements granted for reducing carbon emissions and therefore, treating such income as Profits and Gains of Business or Profession' is incorrect and bad in law. 11. The Ld. CIT (A) erred in upholding that the AO is opinion that such claim ... fact that sale of RECs are capital in nature and hence the same cannot be chargeable to tax under the head "Profits and Gains from Business and Profession." 15. Ld. CIT (A) ought to have appreciated the fact that assessee is eligible for exemption/ deduction even if the same

BIJAY KUMAR GARODIA,,KOLKATA vs. DCIT, CENTRAL CIRCLE 3(4),, KOLKATA

In the result, the appeal of the revenue is dismissed

ITA 2938/KOL/2025[2013-2014]Status: DisposedITAT Kolkata05 Mar 2026AY 2013-2014

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 132Section 132(1)Section 143(3)Section 250Section 271A

assessee/individual/company to have five different sources of income, each one of it will be chargeable to tax under the Act. Profits and gains of business or profession is only one of the heads under which an assessee’s income is liable to be assessed to tax. If an assessee

DY. COMMISSIONER OF INCOME-TAX CENTRAL CIRCLE - 6(2), MUMBAI, MUMBAI vs. TATA AIG GENERAL INSURANCE CO. LTD, MUMBAI

Accordingly, Ground No.2 of the assessee is allowed

ITA 2403/MUM/2024[2018-19]Status: DisposedITAT Mumbai05 Mar 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Ritesh Misra (CIT DR)

Section 10(38)Section 111ASection 112Section 139(1)Section 143(3)Section 234ASection 234BSection 234DSection 250

assessee is that the Ld. AO wrongly treated the profit on sale of investments as income taxable under the head "Profits and Gains of Business or Profession" instead of under the head "Capital Gains,” as declared in the computation of income. 12. The aforesaid issue has already been examined

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 6(2), MUMBAI, MUMBAI vs. TATA AIG GENERAL INSURANCE CO. LTD, MUMBAI

In the result the appeal of the revenue’s bearing ITA No

ITA 2398/MUM/2024[2020-21]Status: DisposedITAT Mumbai05 Mar 2026AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Ritesh Misra (CIT DR)

Section 10(38)Section 111ASection 112Section 139(1)Section 143(3)Section 234ASection 234BSection 234DSection 250

assessee is that the Ld. AO wrongly treated the profit on sale of investments as income taxable under the head “Profits and Gains of Business or Profession” instead of under the head “Capital Gains,” as declared in the computation of income. 12. The aforesaid issue has already been examined ... deduction on account of reversal of such expenses which had earlier been offered to tax. While computing income under the head “Profits and Gains of Business or Profession,” the Ld. AO held that the said claim was not allowable in view of Rule 5 of the First Schedule

TATA AIG GENERAL INSURANCE COMPANY LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME-TAX-8(3)(1), MUMBAI

In the result the appeal of the revenue’s bearing ITA No

ITA 1450/MUM/2024[2018-19]Status: DisposedITAT Mumbai05 Mar 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Ritesh Misra (CIT DR)

Section 10(38)Section 111ASection 112Section 139(1)Section 143(3)Section 234ASection 234BSection 234DSection 250

TATA AIG GENERAL INSURANCE COMPANY LIMITED (TAGIC),MUMBAI vs. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, ASSESSMENT UNIT, INCOME-TAX DEPARTMENT

ITA 1432/MUM/2024[2020-21]Status: DisposedITAT Mumbai05 Mar 2026AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Ritesh Misra (CIT DR)

Section 10(38)Section 111ASection 112Section 139(1)Section 143(3)Section 234ASection 234BSection 234DSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E”, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND SHRI JAGADISH, ACCOUNTANT

PLASCOM INDUSTRIES LLP,KOLKATA vs. THE INCOME TAX OFFICER, WARD-1(3), GUWAHATI

In the result, appeal of the assessee is allowed

ITA 280/GTY/2025[2023-24]Status: DisposedITAT Guwahati02 Mar 2026AY 2023-24

Bench: SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI LAXMI PRASAD SAHU (Accountant Member)

For Appellant: S.M. Surana, AdvocateFor Respondent: Sanjay Jha, JCIT

Section 133(6)Section 142(1)Section 250Section 801ESection 801E(3)Section 801E(4)Section 801E(5)Section 801E(6)Section 80I

which is allowed as a deduction (whether by way of depreciation or otherwise) in computing the income chargeable under the head "Profits and gains of business or profession of any one previous year, It can thus be seen that additional depreciation can be claimed and allowed only when new machinery

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, EXEMPTIONS, CIRCLE-1, , BANGALORE

ITA 355/BANG/2024[2017-18]Status: DisposedITAT Bangalore02 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Sudheendra B.R, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT-DR

Section 11Section 11(1)Section 13(8)Section 143(3)Section 153(1)Section 2(15)Section 250Section 43B

insofar as the disallowance made u/s. 13(8) of the Act and treated the income under the head “Profits and Gains of Business or Profession”. Thereafter the Ld.CIT(A) had considered the other disallowances and granted partial relief. 7. The assessee not satisfied with the orders of the Ld.CIT

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