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TDS Credit Cannot Be Denied Due to Reporting Mismatch

January 30, 2026 1515 Views 0 comment Print

The dispute concerned denial of TDS credit citing inconsistencies in reported transaction values. The ruling clarified that Form 26AS is decisive for TDS credit when deduction and deposit are undisputed.

Section 68 Additions Rejected as Loan Repayment and Cash Sales Explained

January 30, 2026 2301 Views 0 comment Print

The Tribunal upheld deletion of additions where loan repayments were sourced from stock sales and fresh loans. It ruled that without rejecting books or disproving records, section 68 cannot be invoked.

RTGS Sale Proceeds via Credit Society Not Unexplained Money

January 30, 2026 423 Views 0 comment Print

The Tribunal considered whether RTGS credits constituted unexplained money. It ruled that once sale bills, customer ledgers, and bank entries align, Section 69A has no application.

Legal Heir Participation Cannot Cure Invalid U/s 153C Jurisdiction

January 30, 2026 387 Views 0 comment Print

The decision reiterates that once the assessees death is known, proceedings must restart with a valid notice to the legal heir. Failure to do so makes the assessment unsustainable.

Income Tax Appeals Dismissed Due to NCLT Moratorium Against Personal Guarantors

January 30, 2026 339 Views 0 comment Print

This case addressed whether tax appeals survive a moratorium under insolvency law. The ruling confirms that income tax proceedings stand stayed once a moratorium is imposed.

Unsecured Loans Through Banking Channels Accepted; Section 68 Addition of ₹2.87 Cr Deleted

January 30, 2026 717 Views 0 comment Print

Emphasising settled law, the Tribunal ruled that properly documented loan transactions cannot be rejected without cogent contrary material. The CIT(A)s deletion of additions was therefore affirmed.

Final Orders After DRP Beyond Section 153 Limit Quashed Despite Pending Supreme Court Reference

January 30, 2026 621 Views 0 comment Print

The issue was whether final assessment orders passed after DRP directions were barred by limitation under section 144C read with section 153. The Tribunal held that such orders passed beyond the statutory time limit are without jurisdiction and must be quashed.

Cash Advance Adjusted Through Tripartite Deal Not Unexplained Cash Credit U/s 68

January 30, 2026 291 Views 0 comment Print

The Tribunal examined suspicion surrounding a large cash advance for property. It ruled that suspicion alone cannot replace evidence, and once the transaction is substantiated, section 68 addition must be deleted.

Final Assessment Ignoring DRP Directions Held Void; No Post-Limitation Cure Permissible

January 30, 2026 738 Views 0 comment Print

The Tribunal held that a final assessment passed without giving effect to binding DRP directions violates section 144C. Such an order is void ab initio and cannot be sustained once the statutory time limit has expired.

Section 153C Assessments Beyond Ten-Year Block Invalid: Deemed Search Date Starts from Satisfaction Note

January 30, 2026 639 Views 0 comment Print

It was ruled that the date of recording the satisfaction note is the deemed search date for a non-searched person. The ten-year limitation must be counted from this date, not from the original search.

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