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Audit Objection-Driven Reopening Invalid Without AO’s Satisfaction: ITAT Ahmedabad

January 17, 2026 402 Views 0 comment Print

Where capital subsidy was not received in the relevant year and no addition followed, reopening lacked basis. Mechanical reliance on audit objections was held unlawful.

On-Money Addition Fails Without Corroborative Evidence: ITAT Delhi

January 17, 2026 300 Views 0 comment Print

The issue was whether a seized loose paper alone can justify an on-money addition under section 69. ITAT held that without independent corroboration, such addition cannot be sustained.

Section 153C Assessments Quashed for Consolidated Satisfaction Note

January 17, 2026 564 Views 0 comment Print

The Tribunal examined whether a single, consolidated satisfaction note for multiple assessment years meets the requirement of Section 153C. It held that such consolidated recording vitiates jurisdiction, rendering the search assessments void.

Section 153A Additions Sustained Where Incriminating Material Exists: ITAT Ahmedabad

January 17, 2026 414 Views 0 comment Print

The Tribunal upheld additions in search assessments where seized material and settled precedent supported the Revenue’s case. The ruling clarifies that group-level incriminating evidence can justify section 153A additions.

ITAT Ahmedabad Deletes Penalty u/s 271(1)(c): Defective SCN & Partial Quantum Relief Fatal to Penalty

January 17, 2026 315 Views 0 comment Print

The issue was whether a penalty can survive when the show cause notice fails to specify the exact charge. ITAT held that a vague notice violates law, making the entire penalty unsustainable.

Ex-Parte 153A Orders for Six Years Set Aside for Justice

January 17, 2026 579 Views 0 comment Print

The issue was whether six years of search assessments could stand when the first appeal was dismissed ex-parte. ITAT held that denial of meaningful hearing violates natural justice and remanded the matters for fresh adjudication.

Assessments Quashed for Invalid Section 153C Satisfaction Note

January 17, 2026 267 Views 0 comment Print

The case addressed the legality of assessments framed pursuant to a search when the satisfaction note lacked statutory particulars. The Tribunal quashed all assessments, holding them non-est in law due to invalid satisfaction.

ITAT Lucknow Upholds Reopening u/s 150; Deletes Unsecured Loan Addition

January 17, 2026 309 Views 0 comment Print

The Tribunal held that reopening based on a specific appellate direction is legally valid under section 150(1). The key takeaway is that such directions must be challenged separately and cannot be questioned collaterally in reassessment proceedings.

TDS Credit Denied to Non-Signatory Property Co-Owner: ITAT Ahmedabad

January 17, 2026 360 Views 0 comment Print

The issue was whether TDS credit can be claimed by a person not named in the sale deed. ITAT held that TDS credit belongs only to the actual owners who executed the sale agreement.

ITAT Bangalore Upholds Cancellation of 12AB Registration for Influencing Media Content

January 17, 2026 681 Views 0 comment Print

The Tribunal upheld cancellation after finding that funding practices influenced editorial content and political narratives. The ruling confirms that such conduct constitutes specified violations warranting loss of charitable status.

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