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Archive: December, 2025

Posts in December, 2025

Will-Based Mutation Cannot Be Rejected Merely on Objection by Third Party

December 20, 2025 987 Views 0 comment Print

The issue was whether mutation could be refused solely because it was sought on the basis of a will. The Supreme Court held that such refusal was erroneous and restored mutation, clarifying that mutation is fiscal and subject to civil adjudication.

Reassessment Quashed Because Section 151 Sanction Was Mechanical

December 20, 2025 582 Views 0 comment Print

The ITAT held that approval merely stating “Yes, I am satisfied” shows no application of mind. Such sanction fails the statutory requirement and invalidates reopening.

Repaid Loans and Bank Entries Can’t Trigger Section 68

December 20, 2025 546 Views 0 comment Print

The ITAT held that loans and advances accepted in earlier scrutiny assessments cannot be doubted later without fresh incriminating material. Mere balance-sheet analysis or suspicion is insufficient.

JAO Can’t Bypass Faceless Mandate – U/s 148 Notice Issued Outside Scheme Quashed

December 20, 2025 816 Views 0 comment Print

The ITAT held that a reassessment notice issued by the Jurisdictional AO after 29-03-2022 violated the mandatory faceless reassessment scheme. Such a jurisdictional lapse vitiates the entire proceedings.

Less Than 7 Days’ Reply Time Voids Faceless Assessment

December 20, 2025 669 Views 0 comment Print

The High Court held that granting less than seven days to reply to a show-cause notice violates mandatory SOPs. Such a breach vitiates the entire faceless assessment process.

Section 36(1)(iii) Disallowance on Group Loans Remanded

December 20, 2025 588 Views 0 comment Print

The ITAT held that disallowance under Section 36(1)(iii) requires factual verification of business purpose. Interest-free loans to group entities were sent back for fresh examination.

No U/s 115BBE Tax Because Income Was Business Profit, Not Unexplained Money

December 20, 2025 825 Views 0 comment Print

The ITAT held that unrecorded sales cannot be taxed in full under Section 69A. Only the profit element at a reasonable GP rate is assessable as business income.

RBI (Urban Co-operative Banks – Interest Rates on Advances) Directions, 2025

December 20, 2025 561 Views 0 comment Print

The central bank has laid down fresh directions requiring transparent, Board-approved interest rate frameworks for urban co-operative banks. The key takeaway is stronger safeguards against excessive interest and clearer disclosures to borrowers.

RBI (Urban Co-operative Banks – Transfer and Distribution of Credit Risk) Directions, 2025

December 20, 2025 540 Views 0 comment Print

The 2025 Directions confine UCBs to selling only stressed loans and bar them from acting as transferees. The move aims to limit risk build-up and ensure disciplined balance-sheet clean-up.

Borrowed Satisfaction Invalidates Reopening Under Section 147

December 20, 2025 603 Views 0 comment Print

The ITAT held that reassessment based purely on an Investigation Wing report, without the Assessing Officer forming an independent belief, is invalid. Copy-pasted reasons failed to establish a live link between material and escapement of income.

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