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ITAT Mumbai Deletes On-Money Additions u/s 69/69B; No Cross-Examination of Excel Data

January 23, 2026 702 Views 0 comment Print

The Tribunal deleted additions made solely on third-party Excel data after holding that denial of cross-examination of the key witness violated natural justice. The ruling confirms that such denial is fatal where the statement forms the foundation of the addition.

Penalty on Estimated Bogus Purchases Unsustainable: ITAT Pune

January 23, 2026 582 Views 0 comment Print

The issue was whether penalty under section 271(1)(c) can be levied when bogus purchases are disallowed on an estimated basis. The Tribunal held that estimation does not establish concealment, making the penalty unsustainable.

ITAT Mumbai Quashed Section 69 On-Money Additions for Natural Justice Breach

January 23, 2026 1122 Views 0 comment Print

The case examined additions made in Section 153C assessments based on third-party search material. The Tribunal ruled that additions cannot stand unless incriminating documents are furnished to the assessee.

Cash Gifts From Relatives Not Taxable; Section 68 Addition Quashed by ITAT Kolkata

January 23, 2026 2004 Views 0 comment Print

The Tribunal held that cash gifts received from relatives covered under section 56(2)(vii) cannot be taxed as unexplained credits. Once identity, creditworthiness, and genuineness are proved, section 68 has no application.

153C Time-Barred: ITAT Kolkata Quashes Notice Based on Seized Digital Material

January 23, 2026 414 Views 0 comment Print

The issue was whether Section 153C proceedings could continue when seized material was handed over after 01.04.2021. The Tribunal ruled that such notices are barred by law, rendering the assessment void.

ITAT Delhi Deletes Share Capital & 56(2)(viib) Additions: DCF Valuation Upheld

January 23, 2026 381 Views 0 comment Print

The case examined whether the Assessing Officer could reject a DCF valuation. The Tribunal held that commercial valuation choices, if legally prescribed and supported, cannot be second-guessed.

Section 69A Addition on Seized Cash Notings Quashed: Tea Estate Receipts Not Taxable in Director’s Hands

January 23, 2026 531 Views 0 comment Print

The Revenue treated seized cash entries as unexplained income under Section 69A. The Tribunal ruled that receipts from agricultural activities are exempt and cannot be taxed merely based on seized notings.

Penalty Deleted Where Income Already Disclosed & Additions Lead to Double Taxation

January 23, 2026 558 Views 0 comment Print

The Tribunal held that penalty cannot survive where sales were already offered to tax and later added again under section 68. The key takeaway is that double taxation cannot result in penalty when no tax was sought to be evaded.

Section 43B Satisfied When Gratuity Liability Is Genuinely Discharged: ITAT Delhi

January 23, 2026 444 Views 0 comment Print

The Tribunal held that gratuity liability transferred to another employer on employee transfer constitutes valid discharge. Deduction cannot be denied merely because payment was not made directly to the employee.

DRP Final Orders Quashed as Time-Barred Under Sections 144C & 153

January 23, 2026 846 Views 0 comment Print

The issue was whether final DRP-based assessments passed beyond statutory timelines are valid. The Tribunal held that limitation under Section 144C must be read with Section 153, rendering delayed final orders void.

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