“tax benefit”

Chapter X-A - GAARSection 102(10)Section 102(10)634 judgments

S.S. JAIN SABHA GOLF LINK, LUDHIANA,LUDHIANA vs. CIT EXEMPTIONS, JALANDHAR

ITA 482/ASR/2024[24-25]Status: DisposedITAT Amritsar20 Mar 2026

Bench: Dr. Dipak P. Ripote & Sh. Udayan Dasgupta

accordance with the objectives as enumerated in its MOA. 5) The appellant operates exclusively for religious purposes and does not seek to misuse any tax benefits. The cancellation provisions were introduced to address the misuse of trust funds for private gain, which is not applicable in this case. The society

COROMANDEL INTERNATIONAL LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(2), HYDERABAD

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

ITA 738/HYD/2025[2015-2016]Status: DisposedITAT Hyderabad18 Mar 2026AY 2015-2016

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.738/Hyd/2025 ("नधा"रणवष"/ Assessment Year:2015-16) Coromandel International Vs. Dcit, Limited, Circle-2(2), Hyderabad. Hyderabad. Pan: Aaacc7852K (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri Sp Chidambaram, Advocate Assessee Represented By राज"वका""त"न"ध"व/ : Ms. U. Mini Chandran, Cit-Dr Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 02/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 18/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Coromandel International Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 24/02/2025 For The Assessment Year (“A.Y.”) 2015-16. Page 1 Of 17 Coromandel International Limited Vs. Dcit 2. The Assessee Has Raised The Following Grounds Of Appeal:

Section 250Section 32Section 32(1)(ii)Section 35

settled principle of law that unless expressly provided by the statute the same transaction cannot ordinarily give rise to a double tax benefit under the provisions of the Act. Permitting the assessee to treat the same amount as a depreciable asset would effectively result in a double tax advantage arising

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)

deduction of Rs. 2,88,00,000/- u/s 80G of the Act for amounts compulsorily spent under CSR which would result in an indirect tax benefit, defeating the purpose of Explanation 2 to Section 37(1) of the Act? 2. The appellant craves leave to amend or alter any ground

GANESHARAM GALBARAM MALI ,MUMBAI vs. DCIT, CENTRAL CIRCLE 4(2), MUMBAI

In the result the appeals of the assessee bearing ITA No

ITA 8349/MUM/2025[2017-18]Status: DisposedITAT Mumbai12 Mar 2026AY 2017-18

Section 132Section 153CSection 250Section 69Section 69C

such cash on-money and it might be their own\nmoney which they had brought into books in garb of cash on-money for tax benefit.\n8.6 We are of opinion that though the Rubberwala Group has admitted receipt of unaccounted\ncash and offered a percentage thereof to tax, such

GANESHARAM GALBARAM MALI ,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

In the result the appeals of the assessee bearing ITA No

ITA 8348/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Mar 2026AY 2018-19

Bench: Us.

For Appellant: Shri Bharat Kumar, CAFor Respondent: Shri Arun Kanti Datta (CIT DR)

Section 132Section 132(4)Section 153CSection 250Section 69C

such cash on-money and it might be their own money which they had brought into books in garb of cash on-money for tax benefit. 8.6 We are of opinion that though the Rubberwala Group has admitted receipt of unaccounted cash and offered a percentage thereof to tax, such

GANESHARAM GALBARAM MALI ,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

In the result the appeals of the assessee bearing ITA No

ITA 8347/MUM/2025[2019-20]Status: DisposedITAT Mumbai12 Mar 2026AY 2019-20

Bench: Us.

For Appellant: Shri Bharat Kumar, CAFor Respondent: Shri Arun Kanti Datta (CIT DR)

Section 132Section 132(4)Section 153CSection 250Section 69C

SUPERTECH EV LIMITED,JHAJJAR vs. ITO EXEMPTION WARD, ROHTAK

In the result the appeal of the assessee is allowed

ITA 6603/DEL/2025[2024-25]Status: DisposedITAT Delhi11 Mar 2026AY 2024-25

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2024-25 Supertech Ev Limited Vs. Adit, Cpc, Bengaluru/ Ito Plot No.150 Sector 16 Exemptions Ward Rohtak Phase 1 Bahadurgarh Jhajjar Haryana-124507 Pan No.Abjcs1671E (Appellant) (Respondent)

Section 115BSection 143(1)Section 154Section 234B

that even if a procedural delay occurs due to "gemuine hardship", it should not prevent an assessee from receiving a rightful tax benefit. Therefore, in light of the aforesaid judgments of Hon'ble Supreme Court and Hon'ble High Courts, we are of the view that filing of Form

GE ENGINE SERVICES LLC,UNITED STATES OF AMERICA vs. ASSISTANT COMMISSIONER OF INCOME TAX, NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 3700/DEL/2023[AY 2021-22]Status: DisposedITAT Delhi11 Mar 2026

Section 143(2)Section 143(3)Section 144CSection 9(1)

ACIT(supra), Wild West Domains,\nLLC vs ACIT(supra) and Go Daddy.com LLC Vs. DCIT where it is held that to\navail the tax benefit under the treaty it was not necessary that the assessee should be\npaying the actual taxes but what was important that the assessee was liable

TRIVENI TURBINE LTD,NOIDA vs. ACIT, CIRCLE 5(3)(1), NOIDA

In the result, the appeal of the assessee is dismissed

ITA 1061/DEL/2023[2018-19]Status: DisposedITAT Delhi16 Feb 2026AY 2018-19

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay[Assessment Year: 2018-19]

Section 135Section 143(3)Section 144BSection 234ASection 35Section 37(1)Section 80GSection 80G(2)(a)

expenditure, despite the explicit prohibition under Explanation 2 to Section 37(1) and the legislative intent to disallow CSR-related tax benefits. Issue in brief as per AO: 1. Disallowance of Deduction Under Section 35(2AA)[Page 13, Para 5.1): The assessee claimed a weighted deduction

DCIT, CIRCLE-1(1)(1), AHMEDABAD, AHMEDABAD vs. ADANI LOGISTICS LTD, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

ITA 1837/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad12 Feb 2026AY 2020-21

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Years: 2020-21

Section 143(3)Section 14ASection 37(1)Section 80G

deduction of Rs. 29,10,000/- u/s 80G of the Act for amounts spent under mandatory CSR obligation which would result in an indirect tax benefit, defeating the purpose of Explanation 2 to Section 37(1) of the Act?. 3. The appellant craves leave to amend or alter any ground

INCOME TAX OFFICER- 22(1)(6), MUMBAI vs. ARVIND PREMCHAND JAIN, MUMBAI

In the result the appeal filed by the revenue is dismissed

ITA 2878/MUM/2025[2015-16]Status: DisposedITAT Mumbai11 Feb 2026AY 2015-16

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 10(38)Section 147Section 148Section 250Section 68

which was used by the entry CO No. 136/Mum/2025 Arvind Premchand Jain, Mumbai. operator to provide bogus LTCG and enable the assessee to claim tax benefit through bogus exempt income u/s 10(38) of the Act. 4. However AO noted that assessee claimed total LTCG

DCIT - 19(1), MUMBAI, LALBAUGH vs. BHARAT RAMJI BHAI MANEK, GRANT ROAD MUMBAI

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

ITA 4339/MUM/2025[2014-15]Status: DisposedITAT Mumbai10 Feb 2026AY 2014-15

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

For Appellant: Shri Ronak DoshiFor Respondent: Shri Leyaqat Ali Aafaqui, (SR DR)

Section 10(38)Section 143(3)Section 250

Court condemned colorable devices for tax avoidance, emphasizing that transactions must have commercial purpose beyond tax benefits. ITAT Mumbai: in ITO -24(2)(1), Mumbai v. Kailash Chandra Gupta (HUF) (dated 26.07.2024, relevant to 2025 discussions), the Tribunal recognized the menace of bogus LTCG through penny stocks, upholding additions despite

OSG (INDIA) PRIVATE LIMITED,GURGAON vs. DCIT, CIRCLE-3(1), GURGAON

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

ITA 4925/DEL/2024[2021-22]Status: DisposedITAT Delhi04 Feb 2026AY 2021-22

Bench: Shri Yogesh Kumar Us & Shri Brajesh Kumar Singh

Section 143(3)Section 144B

even from other group companies. If any other OSG group company provides the same product, India will lose the GST and the Income tax benefits. The list of large customers includes Honda, Nissan, Suzuki, Yamzen (a trading house), L&T and Tata Motors. The benefit analysis cannot always be direct

SEKAR GOVINDASWAMY,BANGALORE vs. INCOME TAX OFFICER, WARD-3(3)(1), BANGALORE

In the result, appeal filed by the assessee is allowed

ITA 1989/BANG/2025[2021-22]Status: DisposedITAT Bangalore03 Feb 2026AY 2021-22

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2021-22 Shri. Sekar Govindaswamy, Addl/Jcit(A) - 1, No.306 Theja Sunshine Complex, Ludhiana. 16Th D Cross Pai Layout, K. R. Puram, Vs. Bangalore – 560 008, Karnataka. Pan No : Ayyps 5005 R Appellant Respondent Appellant By : Shri. Anto Joseph, Ca Respondent By : Shri. Ganesh R Ghale, Advocate, Standing Counsel For Revenue. Date Of Hearing : 10.11.2025 Date Of Pronouncement : 03.02.2026

For Appellant: Shri. Anto Joseph, CAFor Respondent: Shri. Ganesh R Ghale, Advocate, Standing Counsel for Revenue

Section 115Section 115BSection 139(1)Section 139(4)Section 143(1)Section 154Section 250

115BAC of the Act. Page 5 of 7 9. Thus, the only issue raised and contested by the assessee is about the rejection of tax benefit under the new regime for non-filing of the form 10IE on or before the due date specified under section ... same day i.e., on 17.02.2022 & exercised his option. It is to be noted that the assessee in his return also claimed the tax benefit as per the new tax regime as per provision contained in section 115BAC of the Act. The main contention of the assessee is that Form No.10IE

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

ITA 294/BANG/2025[2021-22]Status: DisposedITAT Bangalore30 Jan 2026AY 2021-22

For Appellant: \nShri Padamchand Kincha, CAFor Respondent: \nShri Shivanad Kalakeri, CIT (DR)

Section 250Section 254Section 37Section 90

nscale and market the products and services in a more focused and\nseamless manner across global markets.\n24.6 The transfer was not undertaken for tax benefits but for\noperational efficiency, market positioning and strategic alignment. The\nvaluation of assets was not carried out by the assessee internally but\nwas entrusted

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 293/BANG/2025[2020-21]Status: DisposedITAT Bangalore30 Jan 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)

Section 250Section 254Section 37Section 90

scale and market the products and services in a more focused and seamless manner across global markets. 24.6 The transfer was not undertaken for tax benefits but for operational efficiency, market positioning and strategic alignment. The valuation of assets was not carried out by the assessee internally but was entrusted

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 292/BANG/2025[2019-20]Status: DisposedITAT Bangalore30 Jan 2026AY 2019-20

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)

Section 250Section 254Section 37Section 90

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

ITA 291/BANG/2025[2018-19]Status: DisposedITAT Bangalore30 Jan 2026AY 2018-19

For Appellant: \nShri Padamchand Kincha, CAFor Respondent: \nShri Shivanad Kalakeri, CIT (DR)

Section 250Section 254Section 37Section 90

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 290/BANG/2025[2017-18]Status: DisposedITAT Bangalore30 Jan 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)

Section 250Section 254Section 37Section 90

HERE SOLUTIONS INDIA PRIVATE LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (CIRCLE 4(2)(1), MUMBAI), MUMBAI

In the result, appeal of the assessee is allowed

ITA 6658/MUM/2025[2022-2023]Status: DisposedITAT Mumbai30 Jan 2026AY 2022-2023

Bench: Smt. Beena Pillai & Shri Girish Agrawalassessment Year: 2022-23

For Appellant: Shri Ketan Ved, CAFor Respondent: Shri Pravin Salunkhe, Sr. DR

Section 144C(5)Section 37Section 37(1)Section 80GSection 80G(1)(i)Section 80G(5)

through General circular no. 01/2016 dated January 12, 2016 (FAQ No. 6) and has clarified on the issue as follows: "Question No. 6: What tax benefits can be availed under CSR? Answer: No specific tax exemptions have been extended to CSR expenditure per se. The Finance Act, 2014 also clarifies

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