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Accommodation Entry Cases: Full Addition Applies Without Proof

January 15, 2026 1314 Views 0 comment Print

Mumbai ITAT held that unexplained bank credits are fully taxable under Section 68 when beneficiaries of accommodation entries are not identified. Mere claim of acting as an entry operator does not limit addition to commission income.

Borrowed Satisfaction from Investigation Wing Not Permissible

January 15, 2026 1218 Views 0 comment Print

The Tribunal ruled that reassessment based on borrowed satisfaction, without inquiry or verification by the AO, is unsustainable. Independent application of mind is mandatory under the new regime.

Block of Assets Continues If New Asset Added Before Year-End: ITAT Mumbai

January 15, 2026 381 Views 0 comment Print

ITAT Mumbai held that a block of assets does not cease if a new asset is added before 31 March. Consequently, no short-term capital gain under Section 50 can be levied.

ITAT Upholds 5% Addition Where Purchases Linked to Sales

January 15, 2026 321 Views 0 comment Print

The Tribunal confirmed that once goods are shown to be sold, purchases cannot be treated as wholly fictitious. A limited addition to cover possible inflation was held justified.

Cash Deposit Reassessment Set Aside for Lack of Valid Sanction: ITAT Delhi

January 15, 2026 1539 Views 0 comment Print

Despite large additions for alleged unexplained cash deposits, the Tribunal quashed the reassessment itself. It reaffirmed that jurisdiction cannot be assumed without proper and reasoned approval.

LTCG on Firm Dissolution Sent Back for Fresh Verification

January 15, 2026 489 Views 0 comment Print

The Tribunal held that deletion of long-term capital gains without examining original partnership records was premature. The matter was remanded for fresh verification of facts and documents.

Electronic Evidence Requires Cross-Examination Before Addition: ITAT Delhi

January 15, 2026 384 Views 0 comment Print

The Tribunal held that additions based solely on third-party statements and seized digital data cannot survive without allowing cross-examination. The matter was remanded for fresh adjudication after granting due opportunity to the assessee.

Unexplained Investment Limited to Actual Payment Made in the Year: ITAT Mumbai

January 15, 2026 783 Views 0 comment Print

The Tribunal ruled that additions under section 69 cannot exceed the amount actually invested during the relevant year. Where most payments were loan-funded, only the year-specific payment required examination.

Reopening After 3 Years Barred If Escapement Below ₹50L: ITAT Delhi

January 15, 2026 897 Views 0 comment Print

ITAT Delhi quashed reassessment issued beyond three years where alleged escapement was only ₹35 lakh. Section 149 bars reopening unless the ₹50-lakh threshold is satisfied.

Loss on Share Sale Is Capital Loss, Not Expense: ITAT

January 15, 2026 414 Views 0 comment Print

ITAT Chennai held that loss on sale of shares must be treated as long-term capital loss. Wrong accounting classification cannot convert it into a disallowable expense.

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