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Archive: 21 December 2025

Posts in 21 December 2025

Penalty Quashed Due to Vague 271(1)(c) Notice Without Specifying Charge

December 21, 2025 162 Views 0 comment Print

The issue was whether a penalty could survive when the notice failed to specify the exact limb of section 271(1)(c). The ITAT held such ambiguity fatal, quashing the entire penalty as void.

Final Assessment Quashed for Missing One-Month DRP Deadline

December 21, 2025 252 Views 0 comment Print

The issue was whether the final order was passed within the statutory timeline after DRP directions. The Tribunal held that delay beyond one month under section 144C(13) renders the order void.

Loss-Making Co-operative Society Not Liable on Bank Deposits

December 21, 2025 207 Views 0 comment Print

The dispute involved taxing deposits despite a declared loss. The Tribunal held that when accounts show a loss, blanket addition of deposits is unsustainable.

Section 12A Order Set Aside Due to Breach of Natural Justice

December 21, 2025 117 Views 0 comment Print

The High Court held that denying continuation of registration by relying on an undisclosed investigation report violates natural justice. Since the trust was not given access to the material used against it, the order was set aside and remanded.

Reassessment Quashed for Wrong Sanction Under Section 151

December 21, 2025 225 Views 0 comment Print

The Tribunal held that reassessment issued beyond three years requires approval from the PCCIT and not the PCIT. Since sanction was obtained from an incompetent authority, the entire reassessment was held void ab initio.

Profit Estimated as Safeguard; Bulk Cash Credit Addition Set Aside

December 21, 2025 267 Views 0 comment Print

The Tribunal upheld deletion of additions where receipts were linked to declared sales and no evidence of cash back was shown. Acceptance of sales negates Section 68 in the absence of proof.

ITAT Grants Last Chance in ₹2.28 Cr Unexplained Property Investment Case

December 21, 2025 174 Views 0 comment Print

ITAT Ahmedabad remanded a ₹2.28 crore unexplained property investment case to the AO, allowing the assessee one final opportunity to provide supporting documents, while imposing a ₹5,000 cost for non-compliance.

Interest from Private Banks Eligible for 80P Deduction: ITAT Pune Clarifies

December 21, 2025 285 Views 0 comment Print

ITAT Pune ruled that interest earned by a cooperative society from ICICI and HDFC banks retains its character as business income and qualifies for deduction under section 80P(2)(a).

Illiteracy and Notice Errors Save ₹2.61 Cr in ITAT Delhi Ruling

December 21, 2025 216 Views 0 comment Print

ITAT Delhi overturned a ₹2.61 crore addition under sections 144/147, noting notices were sent to the wrong address and the illiterate assessee was deprived of proper hearing.

Short Selling Framework Remains Unchanged Despite Media Claims

December 21, 2025 216 Views 0 comment Print

SEBI clarified that reports suggesting new short selling rules from December 22, 2025 were incorrect, confirming that the existing regulatory framework continues unchanged.

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