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Archive: April, 2026

Posts in April, 2026

On-Money Payment Addition Quashed as Excel Sheet & Third-Party Statements Found Unreliable

April 27, 2026 5415 Views 0 comment Print

The Tribunal held that additions cannot be sustained without incriminating material directly connecting the assessee to alleged cash payments. Reliance solely on third-party data was found insufficient. The ruling reinforces the need for concrete evidence in tax additions.

Bogus Purchases – Only 0.2% Profit Addition Sustainable, Consistency Prevails: ITAT Mumbai

April 27, 2026 408 Views 0 comment Print

The Tribunal upheld reduced addition as earlier years’ rulings fixed profit element at 0.2%. It stressed that consistent facts require consistent treatment. Key takeaway: uniform approach must be followed across years.

MCA Expands Fast-Track Mergers, Easing Mid-Market Restructuring Beyond NCLT

April 27, 2026 660 Views 0 comment Print

The MCA introduced a risk-based eligibility framework allowing more companies to access fast-track mergers. By replacing size criteria with debt thresholds, the reform enables quicker approvals. The ruling highlights a shift toward efficiency and reduced judicial intervention.

Penalty on Share Premium Valuation Deleted – Bona Fide Claim Not Concealment

April 27, 2026 426 Views 0 comment Print

ITAT Pune deletes ₹4.83 lakh penalty under Section 271(1)(c), holding that a bona fide difference in share valuation methods (NAV vs DCF) does not amount to furnishing inaccurate particulars; mere rejection of a claim cannot trigger penalty.

NFRA’s TCWG & Auditors Two-Way Communication Sounds Simple – However, Most Governance Structures Are Still Evolving to Achieve I

April 27, 2026 1197 Views 0 comment Print

The issue concerns ineffective communication between auditors and governance bodies despite existing legal requirements. NFRA clarified expectations and pushed for structured engagement, emphasizing accountability and proper documentation.

ITAT Deletes Additions Due to Unreliable Third-Party Evidence in 153C Proceedings

April 27, 2026 549 Views 0 comment Print

The Tribunal held that additions under Section 153C cannot be sustained when based on unverified third-party statements and documents. It found the evidence lacked credibility and was not corroborated. The ruling highlights strict evidentiary standards in search-based assessments.

ITAT Quashes Reopening Due to Vague Reasons Under Section 147

April 27, 2026 507 Views 0 comment Print

The Tribunal held that reopening of assessment is invalid when reasons lack details like transaction nature, parties, and dates. It emphasized that vague information and absence of independent application of mind cannot justify reassessment. The ruling reinforces strict standards for valid reopening under tax law.

ITAT Mumbai: Rule 46A Violation Fatal – CIT(A) Cannot Delete Additions Without AO Verification

April 27, 2026 294 Views 0 comment Print

The Tribunal restored the case as the CIT(A) admitted additional evidence without giving the AO an opportunity to verify it. It held that violation of Rule 46A renders the order procedurally defective.

80P Deduction Denied Due to Late Return? Tribunal Sends Case Back Pending Delay Condonation Decision

April 27, 2026 633 Views 0 comment Print

The case involved disallowance of deduction under Section 80P due to delayed return filing. The Tribunal ruled that the issue must be reconsidered after the authority decides the condonation request.

ITAT Mumbai: Bogus Purchases – Only 12.5% Profit Taxable, Full Disallowance Rejected

April 27, 2026 336 Views 0 comment Print

ITAT observed that the assessee provided invoices, bank records, and tax documents supporting purchases. Since sales were undisputed, full disallowance was unwarranted. The ruling highlights balanced approach in such cases.

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