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Archive: January, 2026

Posts in January, 2026

Section 263 Revision Quashed for Absence of Exempt Income

January 16, 2026 132 Views 0 comment Print

The issue was whether revision could be made to examine disallowance under section 14A despite no exempt income being earned. The Tribunal held that without exempt income, the assessment was neither erroneous nor prejudicial to revenue.

Ex-Parte Appeal Dismissal Set Aside for Lack of Reasoned Order

January 16, 2026 138 Views 0 comment Print

The issue was whether the appellate authority could dismiss an appeal ex-parte without giving detailed reasons. The Tribunal held that a non-speaking order violates section 250(6) and restored the appeal for fresh adjudication.

Reassessment Quashed as JAO Lacked Jurisdiction After Faceless Scheme

January 16, 2026 1233 Views 0 comment Print

The issue was whether reassessment notices could be issued by a jurisdictional officer after the faceless reassessment scheme became mandatory. The Tribunal held that such notices are void, rendering the entire reassessment unsustainable.

Appeal Dismissed on Delay Remanded for Merits Despite Non-Compliance

January 16, 2026 711 Views 0 comment Print

The issue was whether an appeal involving large additions could be dismissed solely for delay without examining merits. The Tribunal held that technical dismissal was improper and ordered remand with costs. Key takeaway: meritorious matters should be decided on merits, not limitation alone.

Accepted Closing Cash Cannot Be Treated as Unexplained Income

January 16, 2026 129 Views 0 comment Print

The Tribunal held that once a closing cash balance is disclosed and accepted in a prior year’s scrutiny assessment, it cannot be questioned as unexplained opening cash in a subsequent year.

Appointment Denial Quashed for Ignoring Reasonable Accommodation

January 16, 2026 156 Views 0 comment Print

The Court examined whether procedural rigidity and expired panels could defeat disability rights. It held that denial of employment without reasonable accommodation violates constitutional guarantees and disability law.

Reassessment Quashed for Issuance of Notice Outside Faceless Regime

January 16, 2026 1230 Views 0 comment Print

The issue was whether reassessment could be initiated by a jurisdictional officer after faceless schemes became mandatory. The Tribunal held that notices issued outside the faceless mechanism lack jurisdiction and invalidate the reassessment.

Reopening After 3 Years Invalid If Escapement Is Below ₹50 Lakh

January 16, 2026 621 Views 0 comment Print

Sanjay Champalal Jaiswal Vs ITO (ITAT Pune) Reopening Beyond Three Years Invalid Where Escapement Is Below ₹50 Lakh — ITAT Pune Quashes Reassessment The Pune SMC Bench of the ITAT quashed the reassessment for AY 2016-17, holding that the notice under section 148 dated 27-07-2022 was without jurisdiction, as the alleged income escaping assessment was […]

Section 263 Validly Invoked for Allowing Section 80P in Belated Return

January 16, 2026 279 Views 0 comment Print

The issue was whether deduction under section 80P could be allowed when the return was filed beyond the due date. The Tribunal held that non-compliance with section 80AC made the assessment erroneous, justifying revision under section 263.

Capital Gains Recomputed After Proving Gift-Funded Purchase Cost

January 16, 2026 357 Views 0 comment Print

The dispute concerned denial of property purchase cost where payments were made by a close relative. The Tribunal held that once source and utilization of funds are established, such payments must be allowed as cost of acquisition. Key takeaway

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