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Bogus Purchase Disallowance Restricted to 6% on Estimation by ITAT Delhi

January 8, 2026 492 Views 0 comment Print

The Tribunal held that when corresponding sales are accepted, a full disallowance of alleged bogus purchases is not justified. It restricted the addition to 6% of the purchase value as a reasonable estimate.

Section 68 Addition for mere Non-Compliance to Summons: ITAT Kolkata

January 8, 2026 429 Views 0 comment Print

The AO accepted documents but still made an addition without pointing out defects. The Tribunal ruled that section 68 requires adverse findings, not assumptions.

Foreign Tax Credit Allowed as Form 67 Delay Is Procedural: ITAT Mumbai

January 8, 2026 564 Views 0 comment Print

The Tribunal examined whether delayed filing of Form 67 can defeat a valid FTC claim. It ruled that Rule 128(9) is directory and FTC cannot be denied when substantive conditions are met.

Interest in Form 26AS Not Taxable on Accrual Under Cash System Without Verification: ITAT Mumbai

January 8, 2026 543 Views 0 comment Print

The CPC taxed interest solely based on Form 26AS despite the assessee following the cash method. The Tribunal ruled that taxation requires verification of receipt and remanded the issue to the AO.

Reopening Quashed as Limitation Under Old Regime Expired: ITAT Mumbai

January 8, 2026 594 Views 0 comment Print

The issue was whether a reassessment notice for AY 2015–16 issued after 31 March 2022 was valid. The Tribunal held the notice time-barred and quashed the entire reassessment proceedings.

Reversal of Unclaimed MSMED Interest Cannot Trigger Tax Addition

January 8, 2026 255 Views 0 comment Print

The ITAT held that reversal of MSMED Act interest cannot be taxed if the provision was never claimed as a deduction. The matter was remanded for verification, with directions to delete the addition if the claim is confirmed.

Section 271(1)(c) Penalty Deleted for Revenue-Neutral Loss Claim

January 8, 2026 291 Views 0 comment Print

The ITAT held that penalty cannot be imposed where a capital loss claim was voluntarily withdrawn during assessment. Since no tax benefit was availed, the case did not attract section 271(1)(c).

Interest on Land Acquisition Compensation Taxable as Capital Receipt

January 8, 2026 1326 Views 0 comment Print

The dispute concerned the head of taxation for interest received on enhanced land compensation. The Tribunal ruled that Section 28 interest is an accretion to compensation and cannot be assessed as income from other sources.

Aggregated Cash Payments Cannot Trigger Section 40A(3) Disallowance

January 8, 2026 480 Views 0 comment Print

The ITAT held that cash expenditure cannot be disallowed merely by aggregating payments. Since no payment to any person on a single day crossed the statutory limit, the disallowance was deleted.

Interest-Free Loan Transfer Pricing Adjustment Invalid Without Any Profits

January 8, 2026 372 Views 0 comment Print

The issue was whether interest-free loans to group entities warranted transfer pricing adjustment. The Tribunal held that since business had not commenced and no income was earned, the adjustment was unsustainable.

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