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Income Tax Assessment Upheld Because Amalgamation Was Not Informed to Tax Officer

December 25, 2025 231 Views 0 comment Print

The Tribunal ruled that failure to formally intimate amalgamation sustained the assessment, applying Mahagun Realtors, while striking down mechanical expense disallowances.

Section 271D Penalty Quashed as Time-Barred in Absence of Assessment: ITAT Chennai

December 25, 2025 933 Views 0 comment Print

The Tribunal held that penalties under Section 271D were invalid as they were imposed beyond the limitation period prescribed under Section 275(1)(c).

Estimation of Profit Bars Further Expense Disallowance – AO Cannot Blow Hot and Cold

December 25, 2025 594 Views 0 comment Print

The ITAT ruled that once profits are estimated under Section 145, further disallowances of salary or commission expenses cannot be made from the same books, emphasizing assessment consistency.

Section 271D Penalty Quashed Because Transaction Was Accepted as Genuine

December 25, 2025 291 Views 0 comment Print

The Tribunal held that once cash received was accepted in assessment without any addition, penalty for alleged violation of Section 269SS could not be sustained.

Section 54 Deduction Allowed Despite Non-Deposit in CGAS

December 25, 2025 750 Views 0 comment Print

The Tribunal ruled that failure to deposit capital gains in CGAS does not bar Section 54 relief when the assessee invests in a new house within the prescribed period. The key takeaway is that substantive compliance overrides procedural lapses.

Section 220(2) Interest Invalid Without Section 156 Demand Notice: ITAT Mumbai

December 24, 2025 600 Views 0 comment Print

The Tribunal ruled that section 220(2) interest cannot be charged where the original demand notice showed nil demand, holding that interest arises only after a valid section 156 notice.

Section 263 Quashed Because It Was Used Only for Review of a Completed Assessment

December 23, 2025 348 Views 0 comment Print

The ITAT held that revision is invalid when invoked merely to re-examine an issue already scrutinised by the Assessing Officer.

Section 148 Notice Invalid Because Dispatch Date, Not Signature Date, Determines Issuance

December 22, 2025 456 Views 0 comment Print

The ITAT held that a reassessment notice dispatched after the new law took effect must follow Section 148A, and failure to do so invalidates the entire proceedings.

TDS Credit Cannot Be Denied Merely Because Income Is Taxed in Sister Concern

December 21, 2025 531 Views 0 comment Print

The Tribunal held that once TDS is reflected in Form 26AS and deposited with the government, credit cannot be denied merely on technical grounds.

No 271AAB Penalty for Book-Based Disallowances Without Search Incriminating Material

December 21, 2025 312 Views 0 comment Print

The Tribunal ruled that section 271AAB applies only to undisclosed income found in search, not to routine disallowances from recorded books.

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