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Cheque Payment Claim Rejected, ED Proves Layering of Crime Proceeds

January 6, 2026 468 Views 0 comment Print

The appellants argued that old properties could not be attached under PMLA. The Tribunal rejected this, holding that “value of proceeds of crime” covers such assets when tainted funds are unavailable.

Husband-to-Wife Property Gift Exempt, ₹1.78 Cr Addition Deleted

January 6, 2026 540 Views 0 comment Print

The AO questioned genuineness and love and affection behind the gift. The ITAT held that once relationship and capacity are proved through documents, no addition can survive.

Third-Party Survey Alone Can’t Justify ₹17.50 Lakh Addition

January 6, 2026 486 Views 0 comment Print

The Tribunal ruled that unexplained investment additions cannot stand without concrete proof of actual investment. Mere survey information and assumptions do not shift the burden onto the taxpayer.

No Proof of On-Money, ₹1.52 Cr Buyer Addition Deleted

January 6, 2026 387 Views 0 comment Print

No incriminating material showed payment over the registered consideration. The tribunal held that without independent evidence, the ₹1.52 Cr addition could not be sustained.

No Lack of Enquiry in Loan Verification, PCIT Revision Fails

January 6, 2026 258 Views 0 comment Print

The issue was whether revision could be invoked despite detailed verification of unsecured loans during scrutiny. The ITAT held that once enquiries are duly conducted, section 263 cannot be used for a deeper re-probe.

No Incriminating Material, Section 263 Cannot Override 153A Order

January 6, 2026 501 Views 0 comment Print

The issue was whether revision under section 263 could survive when no incriminating material was found for an unabated year. The tribunal held that without search-based evidence, the completed assessment could not be disturbed.

LLP Cleared of Section 68 Additions Due to Proven Partner Funds

January 6, 2026 504 Views 0 comment Print

The tribunal noted that the firm had no business activity and only earned interest income. It held that unexplained income cannot be presumed in such circumstances when contributors are identified.

Post-2022 Reassessment Fails for Ignoring Faceless Procedure

January 6, 2026 831 Views 0 comment Print

The case examined whether reassessment proceedings could survive when issued outside the faceless mechanism. The ruling confirms that non-compliance with the faceless scheme is a fatal jurisdictional defect.

Section 11 Exemption Allowed Because Late Form 10B Is Procedural

January 6, 2026 3408 Views 0 comment Print

The issue was whether delayed filing of Form 10B bars exemption for a charitable trust. The Tribunal held the delay to be procedural and sustained exemption since audit was completed and report filed during appellate proceedings.

Deduction Disallowance Remanded Because Net Impact Was Nil

January 5, 2026 207 Views 0 comment Print

The issue concerned a large Schedule BP deduction disallowed under section 37. The Tribunal held that prima facie the amounts were both added and allowed in the return, warranting fresh verification by the Assessing Officer.

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