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Archive: December, 2025

Posts in December, 2025

Tax Proceedings Stayed Due to 8–11 Year Delay in Assessment: HP HC

December 29, 2025 606 Views 0 comment Print

The Court stayed tax action after noting an unusually long delay in issuing the assessment notice, holding that further proceedings should remain in abeyance pending clarification from the authorities.

AI Solutions for Business Strategy, Planning and Execution in MSME Startups

December 29, 2025 930 Views 0 comment Print

The case explains how AI helps small enterprises design strategy, improve planning accuracy, and execute daily workflows with measurable gains in margins, cash flow, and reliability.

Defective Sanction under Section 279(1) Vitiates Prosecution: SC

December 29, 2025 873 Views 0 comment Print

The High Court held that prosecution was invalid because the officer who filed the complaint lacked authority under the sanction granted, reinforcing that sanction is a jurisdictional prerequisite.

Notional Addition on Alleged Understatement of Sales — Held Without Authority of Law

December 29, 2025 429 Views 0 comment Print

The Tribunal held that the tax department cannot substitute actual sale consideration with a notional market price without express legal provision, and deleted the entire addition.

Old Cash Withdrawal Claim Rejected for Demonetisation Deposits

December 29, 2025 531 Views 0 comment Print

The Tribunal upheld addition of demonetisation cash deposits after rejecting the claim that funds came from old cash withdrawals. Mere assertion of past withdrawals, without evidence of cash retention, was held insufficient.

Mechanical Appellate Order Quashed for Ignoring Rule 46A

December 29, 2025 465 Views 0 comment Print

The Tribunal found the appellate order mechanical where Rule 46A evidence was filed but not examined. The matter was sent back for fresh adjudication after proper verification.

Interim Compensation Not Taxable Until Final Court Settlement

December 29, 2025 429 Views 0 comment Print

The Tribunal held that compensation received under interim court orders is contingent and does not accrue as income. Taxability arises only in the year when litigation is finally settled and the amount crystallises.

60% Tax Under Section 115BBE Not Applicable Before 1 April 2017

December 29, 2025 630 Views 0 comment Print

The Tribunal held that the enhanced 60% tax rate cannot apply to transactions before 01.04.2017. For AY 2017-18, unexplained cash additions relating to earlier transactions are taxable only at 30%.

Half-Way Condonation Invalid: Time-Barred Appeal Can’t See Merits

December 29, 2025 393 Views 0 comment Print

The Tribunal ruled that once an appeal is rejected as time-barred, the appellate authority cannot adjudicate it on merits. A contradictory approach violates jurisdictional discipline and warrants remand.

NFAC Order Quashed for Casual and Non-Application of Mind

December 29, 2025 219 Views 0 comment Print

ITAT ruled that an appeal cannot be rejected mechanically on alleged defects when records show compliance. The case was remanded for fresh, reasoned adjudication after proper hearing.

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