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Archive: 09 November 2025

Posts in 09 November 2025

ITAT Allows TDS Credit Based on Form 26AS Despite Turnover Mismatch in Books

November 9, 2025 684 Views 0 comment Print

The Tribunal held that TDS credit cannot be restricted solely due to differences between reported turnover and Form 26AS if the assessee has correctly offered the income for tax. The appeal was allowed, directing the AO to grant full TDS credit.

ITAT Mumbai Sets Aside ₹8.9 Cr Loan Addition for Non-Service of Notices via Dysfunctional Email

November 9, 2025 264 Views 0 comment Print

Tribunal held that assessment proceedings were invalid as notices were sent to a non-functional email ID, denying assessee a fair hearing. Case remanded for fresh adjudication.

No Addition Just for Representing Clients in Bogus Share Investigation as a CA

November 9, 2025 6552 Views 0 comment Print

ITAT held that the Assessing Officer made a ₹50 lakh addition solely on estimation without any supporting material, and deleted the addition as no evidence linked the assessee to alleged bogus share transactions.

Ten-Year Section 153A Block to Be Counted from AY of Search Year, Not Before

November 9, 2025 423 Views 0 comment Print

ITAT Delhi held that reassessment for AY 2010-11 was invalid since it exceeded the ten-year limitation from the search year. The notice was declared time-barred and issued without jurisdiction.

Section 153C Notice Beyond Six-Year Block Period Held Invalid: ITAT Delhi

November 9, 2025 333 Views 0 comment Print

TAT Delhi held that a 153C assessment for AY 2012–13 was invalid, as the six-year block must be counted from date of satisfaction recorded by AO of non-searched person.

Section 153C Block Period to Be Counted from Date of Receipt of Seized Material, Not Search Date

November 9, 2025 375 Views 0 comment Print

ITAT Delhi held that ten-year block under Section 153C must be computed from date AO of non-searched person receives seized material, not search date.

₹1.48 Cr Jewellery Addition Deleted as Declared Holdings Exceeded Search Findings

November 9, 2025 483 Views 0 comment Print

ITAT held that no addition under Section 69A was justified when the jewellery found during search was less than the amount already declared in wealth tax returns. Revenue’s appeal was dismissed.

No TDS Liability on Year-End Provisions Without Identified Payees: ITAT Mumbai

November 9, 2025 1071 Views 0 comment Print

ITAT Mumbai held that TDS need not be deducted on year-end expense provisions where payees are unidentifiable and liability crystallizes later. Case remanded for factual verification.

Capital Gains on Development Rights Taxable to Members, Not Society: ITAT Mumbai

November 9, 2025 1194 Views 0 comment Print

ITAT Mumbai held that consideration from a redevelopment agreement is taxable in hands of individual members, not co-operative housing society. Tribunal upheld CIT(A)’s deletion of ₹4.97 crore addition, confirming that society acted merely as a representative.

ITAT Delhi Deletes Double Addition of ₹14.45 Crore Made by CPC

November 9, 2025 717 Views 0 comment Print

ITAT held that once income is accounted in the Profit & Loss statement, further addition by the tax authority is unlawful. The order restores the correct claim of losses and eliminates double addition.

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