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Archive: December, 2025

Posts in December, 2025

FDR Addition Remanded Because AO Failed to Verify Bank Records

December 9, 2025 519 Views 0 comment Print

The Tribunal held that unexplained money addition cannot stand when the AO ignores direct verification from the bank. Matter restored to the AO to summon the bank and tax only actual interest income.

Huge Agricultural Income Accepted as Genuine – No Contrary Evidence from AO

December 9, 2025 1659 Views 0 comment Print

The Tribunal held that agricultural income cannot be disallowed merely due to a year-on-year increase. Since land ownership, crop details, and receipts were undisputed, the addition was deleted.

Delay Condoned Due to Bona Fide Reason: Penalty Appeal Revived

December 9, 2025 450 Views 0 comment Print

The Tribunal condoned a 960-day delay after finding that the assessee’s reliance on VSV settlement and pending rectification was a bona fide cause. It ruled that penalty under Section 271D is independent of quantum proceedings. The penalty appeal was wrongly dismissed as infructuous and has been remanded for fresh decision.

Rs. 5.33 Lakh Mistaken as ₹5.33 Crore: ITAT Rescues Illiterate Villager from Wrong U/s 69A Addition

December 9, 2025 1146 Views 0 comment Print

The Tribunal found that a fixed-deposit mismatch caused an unjustified ₹5.33-crore addition. Delay was condoned and the matter was remanded for fresh assessment with proper verification.

Cash Rebate Allegation of ₹9.06 Cr: Tribunal Rejects 7.5% Theory for Lack of Proof

December 9, 2025 330 Views 0 comment Print

The Tribunal accepted that the 7.5% rebate was a pre-negotiated commercial discount and not an unaccounted cash return. As the seized loose sheets were unverified and unsupported by witnesses, the ₹9.06 crore addition failed.

Form 3CD Errors Not Enough: Tribunal Flags Wrong Business Income Additions

December 9, 2025 411 Views 0 comment Print

Incorrect Form 3CD reporting led CPC to treat rental income and capital gains as business income. The Tribunal ruled that such mismatches cannot justify additions without verification.

Interest From Co-op Banks Counts as Business Income: Section 80P Deduction Granted

December 9, 2025 1167 Views 0 comment Print

The Tribunal ruled that interest from co-operative bank deposits is attributable to business activity and eligible for deduction under Section 80P(2)(a)(i). The disallowance of ₹8.98 lakh was ordered to be deleted.

Reopening Quashed- JAO’s 148 After 29.03.2022 Invalid – Faceless Scheme is Mandatory

December 9, 2025 555 Views 0 comment Print

ITAT Chennai held that a Section 148 notice issued by JAO after 29.03.2022 is invalid, as the faceless assessment scheme is mandatory, nullifying the reassessment order.

Survey Disclosure Treated as Business Income – No Scope for Section 68 Addition

December 9, 2025 462 Views 0 comment Print

ITAT Kolkata ruled that cash advances discovered during a survey must be assessed as business income, not unexplained cash credit under Section 68, making the exercise tax-neutral.

Documentary Trail Wins- Suspicion Cannot Replace Evidence: Penny-Stock Addition Deleted

December 9, 2025 1671 Views 0 comment Print

ITAT Mumbai ruled that detailed records, including Demat statements and contract notes, proved the genuineness of penny-stock transactions, nullifying additions under Sections 68 and 69C.

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