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Archive: May, 2026

Posts in May, 2026

Consolidated Satisfaction Note for Multiple Years Held Invalid – ITAT Quashes Entire U/s 153C Assessments

May 19, 2026 201 Views 0 comment Print

Delhi ITAT held that a single consolidated satisfaction note covering multiple assessment years without identifying year-wise incriminating material is invalid under Section 153C. The Tribunal consequently quashed all related assessments.

HR Manual Cannot Override Approved Gratuity Rules: Calcutta HC

May 19, 2026 264 Views 0 comment Print

Court held that amended gratuity rules effective from July 2013 governed all employees uniformly and prevailed over inconsistent provisions in the HR manual. The appeal seeking enhanced gratuity was dismissed.

Madras HC Upholds Deferred Taxation of Time-Share Fees as Obligations Continued Over Membership Period

May 19, 2026 150 Views 0 comment Print

Madras High Court held that time-share membership fees could not be fully taxed in the year of receipt since the assessee had continuing obligations extending over several years. The Court approved spreading part of the income over the membership tenure.

Purchase of MHADA Leasehold Tenement Can Attract Section 56(2)(x): ITAT Mumbai

May 19, 2026 2634 Views 0 comment Print

Mumbai ITAT held that Section 56(2)(x) applies to purchase of MHADA leasehold property rights despite reliance on Section 50C rulings. However, the Tribunal directed the AO to obtain a DVO valuation before recomputing the addition.

ITAT Deletes Section 68 Addition on Forfeited Loans Already Offered to Tax – Double Taxation Not Permissible

May 19, 2026 144 Views 0 comment Print

Delhi ITAT held that unsecured loans already forfeited and offered to tax in a subsequent assessment year cannot again be taxed under Section 68 in the year of receipt. The Tribunal ruled that such action would result in impermissible double taxation.

Land Acquisition Compensation Not Subject to TDS in Mediated Settlement: Karnataka HC

May 19, 2026 405 Views 0 comment Print

High Court reiterated that compensation awarded for compulsory land acquisition is not liable to deduction of tax at source under Income Tax Act. Payments under mediation settlement were directed to be released without TDS deduction.

Penalty for Fraudulent EPCG Shipping Bills Reduced Due to Principle of Proportional Liability

May 19, 2026 177 Views 0 comment Print

Tribunal upheld findings of fraud involving third-party shipping bills and false export obligation fulfilment but reduced the quantum of penalties. It observed that appellant’s liability could not exceed comparable penalties imposed on principal offenders.

Unsigned Digital Reassessment Notices Held Void – ITAT Quashes Entire 147 Proceedings

May 19, 2026 276 Views 0 comment Print

Delhi ITAT held that notices issued under Sections 148A(b), 148A(d) and 148 without digital signatures are invalid in e-proceedings. The Tribunal quashed the entire reassessment as void ab initio.

Multiple Houses Eligible for Section 54 Relief Prior to 01.04.2015: ITAT Delhi

May 19, 2026 114 Views 0 comment Print

Delhi ITAT held that before the amendment effective from 01.04.2015, exemption under Section 54 could be claimed for investment in more than one residential house. The Tribunal deleted the disallowance relating to the second property purchase.

Unsigned Mauritius Financials Sink Section 68 Defence – ITAT Restores ₹6.30 Crore Share Premium Addition

May 19, 2026 87 Views 0 comment Print

Delhi ITAT restored ₹6.30 crore addition under Section 68 after finding that the Mauritius investor’s financial statements were unsigned and unauthenticated. The Tribunal held that incomplete documents cannot establish identity, creditworthiness or genuineness of transactions.

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