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Archive: 09 January 2026

Posts in 09 January 2026

Section 80P Deduction Cannot Be Denied by CPC for AY 2019-20

January 9, 2026 336 Views 0 comment Print

The issue was whether CPC could disallow Section 80P deduction while processing the return under Section 143(1). The Tribunal held that CPC lacked such power for AY 2019-20 as the enabling amendment came later.

No Penalty for Recharacterising Capital Gains as Business Income

January 9, 2026 450 Views 0 comment Print

The Assessing Officer imposed penalty after treating disclosed capital gains as business income. The Tribunal ruled that classification disputes, without suppression of facts, cannot justify penalty.

Section 69 Addition Quashed Because Housing Loan Explained Source

January 9, 2026 405 Views 0 comment Print

The issue was whether cash and cheque payments could be taxed as unexplained investment in AY 2013–14. The Tribunal held that the major payments pertained to FY 2010–11 and could not be assessed in a later year.

Reopening Quashed for Mechanical “Bogus Sub-Contractor” Reasons

January 9, 2026 303 Views 0 comment Print

The issue was whether reassessment based on identical, template reasons was valid. The Tribunal held that reopening without independent application of mind amounts to borrowed satisfaction and is invalid in law.

No Section 68 Addition When Capital Introduction Pertains to Another Year

January 9, 2026 402 Views 0 comment Print

The Tribunal upheld deletion of a ₹2.27 crore addition after finding that the capital deposit did not pertain to the assessment year in question. Without a year-wise nexus, section 68 could not be invoked.

Low-Margin Trading Business Justifies 2% Profit Estimation

January 9, 2026 615 Views 0 comment Print

The issue was determination of income when the assessee failed to maintain books of account. The Tribunal held that an 8% or 4% estimate was excessive and fixed profit at a reasonable 2% of turnover.

Section 40A(3) Disallowance Set Aside in Invalid Reassessment

January 9, 2026 255 Views 0 comment Print

The case examined whether reassessment after four years was valid when the issues were already examined in scrutiny. The Tribunal held the reopening invalid as a mere change of opinion and quashed the reassessment.

Delay in Filing Condoned for Old Trust, Registration Matter Restored

January 9, 2026 435 Views 0 comment Print

Recognising the non-commercial nature of a long-standing charitable trust, the Tribunal condoned the delay. The registration application was sent back for reconsideration on merits.

Section 270A Penalty Case Remanded After Delay Condoned

January 9, 2026 387 Views 0 comment Print

Where the CIT(A) rejected the appeal only on limitation, the Tribunal intervened. It directed fresh adjudication of the penalty after condoning the 380-day delay.

Specific Performance Granted After POA Ratification Affidavit

January 9, 2026 249 Views 0 comment Print

The Supreme Court held that a subsequent affidavit ratifying acts of a power-of-attorney holder revived the agreement and reset limitation. Once ratification was admitted, refusal to execute sale entitled the buyer to specific performance.

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