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Non-Payment Under IDS Makes U/s 271AAC Penalty Inevitable

December 31, 2025 438 Views 0 comment Print

The dispute concerned cancellation of IDS benefits due to non-payment. The Tribunal held that once IDS lapses, undisclosed income is taxable with mandatory penalty.

VSV-Based Dismissal Quashed Due to No Approval or Payment

December 31, 2025 360 Views 0 comment Print

The dispute centered on whether appeals could be dismissed merely on filing a VSV application. The Tribunal ruled that rejection or non-approval of VSV keeps appeals alive.

Accommodation Entry Purchases Confirmed for Lack of Proof

December 31, 2025 444 Views 0 comment Print

The case involved alleged bogus purchases backed only by invoices and bank payments. The Tribunal held that without confirmations, transport evidence, or delivery proof, such purchases cannot be treated as genuine.

Section 148 Notice Held Premature While Return Filing Window Open

December 31, 2025 594 Views 0 comment Print

The issue was whether reassessment could be initiated while the time to file a belated return was still open. The Tribunal held such reopening premature and void, as income cannot be said to have escaped assessment.

₹13.32 Cr Cash Credit Addition Remanded for Rule 46A Lapse

December 31, 2025 408 Views 0 comment Print

The case involved a massive section 68 addition sustained solely due to non-admission of evidence under Rule 46A. The Tribunal held that procedural lapses cannot override substantive justice and remanded the matter for fresh adjudication.

Borrowed Satisfaction Backfires: ITAT Ahmedabad Quashes 147 Reopenings Based on Dishman Group Search Inputs

December 31, 2025 693 Views 0 comment Print

ITAT held reassessment invalid as it was initiated merely on Insight Portal data and third-party statements without verification or application of mind.

Reassessment on Deceased’s PAN Valid for Pre-Death Years

December 31, 2025 381 Views 0 comment Print

ITAT Mumbai (E Bench) in Estate of Vandravan P. Shah vs ACIT (ITA Nos. 5401, 5402 & 5403/Mum/2024; AYs 2011-12, 2012-13 & 2017-18; order dated 23.12.2025) has partly rejected the assessee’s jurisdictional challenge and upheld the validity of reassessment proceedings initiated and completed in the name of the deceased through legal representative u/s 159, while also sustaining the disallowance of deduction u/s 35AC on alleged bogus donation to Navjeevan Charitable Trust.

On-Money Jewellery Additions Fail Due to Denial of Cross-Examination

December 31, 2025 1023 Views 0 comment Print

ITAT deleted additions as alleged cash jewellery purchases were based solely on third-party material without granting cross-examination or furnishing full evidence.

Section 80IB(10) Disallowance Becomes Academic After Reassessment Is Quashed

December 31, 2025 198 Views 0 comment Print

Once the Bombay High Court has quashed the reassessment notice u/s 148 and all consequential proceedings, the Revenue’s challenge to deletion of deduction u/s 80IB(10) becomes purely academic.

TDS on HUDA EDC Payments Upheld Due to Section 194C Applicability

December 30, 2025 645 Views 0 comment Print

The issue was whether External Development Charges paid to a statutory authority attract TDS. The Tribunal held that such payments are subject to section 194C, following binding High Court precedent.

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