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Archive: 19 February 2026

Posts in 19 February 2026

Mere Third-Party Excel Sheet Insufficient for Section 69 Addition: ITAT Chandigarh

February 19, 2026 5193 Views 0 comment Print

The alleged unexplained investment was based only on third-party statements and seized digital data. In absence of receipts, confirmations, or admission by the assessee, the addition of ₹50 lakh was deleted.

ITAT Guwahati Quashes Reassessment Notice, Treats Loose Sheets as Dumb Documents, Deletes Protective Sec 69C Addition

February 19, 2026 666 Views 0 comment Print

ITAT dismissed the Revenues appeal because it did not contest the CIT(A)s ruling that the reassessment notice was legally invalid. Without challenging the jurisdictional defect, the appeal became infructuous.

CENVAT Credit on employee transportation inadmissible from 01.04.2011

February 19, 2026 198 Views 0 comment Print

CESTAT Chennai held that CENVAT credit on transport coordination services relating to employee movement is inadmissible for the period from 01.04.2011 onwards. Further, CENVAT on escort/security services may qualify as input services if the place of removal extends beyond the factory gate.

ITAT Guwahati Deletes Bogus Loan Addition as Firm’s Liability, Quashes Wrong AY Share Addition

February 19, 2026 255 Views 0 comment Print

The Tribunal held that share transactions relating to an earlier assessment year cannot be taxed in a subsequent year. Since the Revenue failed to link them to AY 2018-19, the addition was deleted.

Compensation paid due to fluctuation loss is allowable business expense

February 19, 2026 231 Views 0 comment Print

Madras High Court held that compensation paid to agent on account of loss due to fluctuations in foreign exchange rate is allowable as business expense under section 37 of the Income Tax Act. Accordingly, disallowance of the same is not justified and liable to be deleted.

ITAT Hyderabad Remands Agricultural Land vs Capital Asset Issue – Directs Proper Sec 2(14) Verification

February 19, 2026 762 Views 0 comment Print

ITAT condoned a 106-day delay considering the assessees senior citizen status and bona fide reasons. On merits, it restored the capital gains issue to the Assessing Officer for de novo verification.

Rejection of Books Upheld but Profit Estimation Reduced to 5% – Self-Made Vouchers Expense Defects Not Fully Reliable – ITAT Hyderabad

February 19, 2026 405 Views 0 comment Print

The Tribunal held that payment towards traffic violation is hit by Explanation 1 to Section 37(1) and not deductible. Though books were rightly rejected, estimation at 8% was moderated to 5% in the interest of justice.

ITAT Chandigarh Deletes “On-Money” Addition – Third-Party Digital Data Insufficient Without Corroboration

February 19, 2026 729 Views 0 comment Print

The Tribunal deleted the addition sustained by the CIT(A) as it was based solely on digital data found from a third party. It reiterated that suspicion or extrapolation without direct evidence cannot sustain tax additions.

ITAT Chandigarh Upholds Sec 271C Penalty – Nodal Govt. Agency Liable for Non-Deduction of TDS U/s 194C

February 19, 2026 315 Views 0 comment Print

The Tribunal held that mere transfer of funds to a state undertaking does not shift statutory TDS liability. Without proof of lawful discharge of TDS, penalty was sustained

Delayed Form 10F Not Fatal for DTAA Benefit – Procedural Requirement Held Curable – ITAT Hyderabad

February 19, 2026 552 Views 0 comment Print

The Tribunal held that denial of India–USA DTAA rates during processing under Section 143(1) was unjustified. It observed that Form 10F facilitates verification and does not create the right, making delayed compliance curable.

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