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Archive: 30 December 2025

Posts in 30 December 2025

Section 263 Appeal Becomes Infructuous After Nil Demand

December 30, 2025 369 Views 0 comment Print

The Tribunal observed that the purpose of revision is to protect revenue interests. When no tax demand arises in consequential proceedings, the revision order no longer calls for adjudication.

Wrong Authority Approval Invalidates Reopening Beyond Three Years

December 30, 2025 588 Views 0 comment Print

The Tribunal ruled that where more than three years have elapsed, sanction must come from the Principal Chief Commissioner. Approval by the Principal Commissioner renders the reassessment void ab initio.

Additions Deleted for Failure to Verify Form 26AS and Pension Income

December 30, 2025 297 Views 0 comment Print

The Tribunal set aside the appellate order after finding that no enquiry was conducted despite clear evidence in Form 26AS. The ruling underscores that undisputed pension income cannot be ignored without verification.

Multipurpose Co-op Societies Get Fresh Look on U/s 80P Claims

December 30, 2025 378 Views 0 comment Print

The Tribunal held that eligibility of deduction on interest from scheduled banks depends on whether funds are operational to the credit business. The matter was remanded to verify the society’s activities and source of funds.

Failure to Seek Delay Condonation Proves Fatal to Trust Appeals

December 30, 2025 480 Views 0 comment Print

The Tribunal dismissed the appeals as time-barred since no application for condonation of delay was filed despite repeated opportunities. In the absence of any explanation, the appeals were held not maintainable.

New Reassessment Law Overrides Old Limitation Extensions

December 30, 2025 777 Views 0 comment Print

The Tribunal held that a notice issued under section 148 on 31.07.2022 for AY 2014-15 was barred by limitation under the amended section 149. Reassessment proceedings were quashed as void ab initio.

World Cup Sponsorship Payment Split Into Ad Spend and Royalty

December 30, 2025 393 Views 0 comment Print

The Delhi High Court held that sponsorship payments included consideration for worldwide use of event trademarks. The ruling confirms that such rights constitute royalty liable to withholding tax.

Video-Recorded Will Upheld, Probate Granted Despite Objections

December 30, 2025 405 Views 0 comment Print

The court relied on a video recording, attesting witness testimony, and medical certification to confirm soundness of mind. Digital evidence was accepted as reliable corroboration of Will execution.

Section 12AB and 80G Applications Revived After Long Delay

December 30, 2025 600 Views 0 comment Print

ITAT Pune condoned an 897-904 day delay in appeals, holding the delay was unintentional and due to incorrect guidance. The case highlights that bona fide professional errors can justify condonation of delay.

Dumb Electronic Documents Cannot Create Taxable Investment

December 30, 2025 270 Views 0 comment Print

Mumbai ITAT upholds deletion of ₹70 lakh under Section 69, ruling that uncorroborated WhatsApp scribbles from a third party cannot establish unexplained cash income.

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