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ITAT Hyderabad: Section 115BAA Benefit Cannot Be Denied on Technicalities; MAT Not Applicable Once Option Validly Exercised

April 27, 2026 168 Views 0 comment Print

The issue was denial of concessional tax regime due to incorrect ITR disclosure and alleged delay in filing Form 10-IC. The Tribunal held that due date depends on the class of assessee, not procedural lapses, and allowed Section 115BAA benefit.

Charitable Trust as Pass-Through Entity: ITAT Deletes Interest Disallowance Rejects 8% Profit Estimation

April 27, 2026 150 Views 0 comment Print

The Tribunal held that interest expenses cannot be disallowed when the trust merely facilitates transactions and costs are reimbursed. It emphasized the concept of real income and pass-through structure.

Security Deposits from Contractors Not Cash Credits: ITAT Upholds Deletion of ₹22.61 Cr Addition

April 27, 2026 159 Views 0 comment Print

The issue was whether contractor deposits could be treated as unexplained credits. The Tribunal held they were genuine trade liabilities, not taxable under Section 68.

Reopening Quashed – Incorrect Facts Cannot Extend Limitation Beyond 3 Years

April 27, 2026 312 Views 0 comment Print

The issue was reopening based on incorrect cash deposit figures exceeding ₹50 lakh. The Tribunal held actual amount was lower, making notice time-barred and invalid.

12.5% Profit on Bank Credits Excessive, Restricted to 4%: ITAT Hyderabad

April 27, 2026 183 Views 0 comment Print

ITAT Hyderabad holds 12.5% profit estimation on ₹2.52 crore bank credits excessive; rejects commission agent claim due to lack of evidence but restricts income estimation to 4%, granting partial relief to the assessee.

Bogus Purchases – Only 0.2% Profit Addition Sustainable, Consistency Prevails: ITAT Mumbai

April 27, 2026 240 Views 0 comment Print

The Tribunal upheld reduced addition as earlier years’ rulings fixed profit element at 0.2%. It stressed that consistent facts require consistent treatment. Key takeaway: uniform approach must be followed across years.

Penalty on Share Premium Valuation Deleted – Bona Fide Claim Not Concealment

April 27, 2026 255 Views 0 comment Print

ITAT Pune deletes ₹4.83 lakh penalty under Section 271(1)(c), holding that a bona fide difference in share valuation methods (NAV vs DCF) does not amount to furnishing inaccurate particulars; mere rejection of a claim cannot trigger penalty.

ITAT Mumbai: Rule 46A Violation Fatal – CIT(A) Cannot Delete Additions Without AO Verification

April 27, 2026 159 Views 0 comment Print

The Tribunal restored the case as the CIT(A) admitted additional evidence without giving the AO an opportunity to verify it. It held that violation of Rule 46A renders the order procedurally defective.

ITAT Mumbai: Bogus Purchases – Only 12.5% Profit Taxable, Full Disallowance Rejected

April 27, 2026 210 Views 0 comment Print

ITAT observed that the assessee provided invoices, bank records, and tax documents supporting purchases. Since sales were undisputed, full disallowance was unwarranted. The ruling highlights balanced approach in such cases.

No Appeal Dismissal u/s 249(4)(b) Without Advance Tax Liability: ITAT Hyderabad

April 27, 2026 102 Views 0 comment Print

ITAT Hyderabad holds that Section 249(4)(b) cannot bar appeal where no income is admitted and no advance tax is payable; sets aside dismissal and directs AO to treat demonetisation cash deposits as business turnover (if normal) and estimate income u/s 44AD instead of Section 69A addition.

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