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Reopening Dropped as Supreme Court Concession on AY 2015-16 Is Binding

January 6, 2026 726 Views 0 comment Print

The Tribunal held that reassessment notices issued after 1 April 2021 for AY 2015-16 are legally unsustainable. Since jurisdiction itself failed under TOLA principles, the entire reassessment was quashed.

Section 10AA Deduction Upheld Despite Late Filing of Return

January 6, 2026 654 Views 0 comment Print

The issue was whether SEZ deduction could be denied for alleged late filing of Form 56F. The Tribunal held that filing within the CBDT-extended deadline was valid and CPC erred in disallowance. The ruling confirms that statutory extensions must be honoured in return processing.

Appeals Dismissed Since Bank Trails Linked NRHM Misappropriation to Assets

January 6, 2026 330 Views 0 comment Print

The issue was whether payments received by private firms were genuine business income or tainted funds. The Tribunal held that advance payments and manipulated tendering showed diversion of NRHM money, justifying attachment.

Disciplinary Action Cannot Be Based on Judicial Orders Alone: SC

January 6, 2026 474 Views 0 comment Print

The Supreme Court reinstated a judicial officer removed solely for granting bail without citing a statute in four cases. The Court emphasized that judicial errors alone cannot justify disciplinary action and awarded full back wages.

Appeals Dismissed Since PMLA Allows Attachment of Property Held by Non-Accused

January 6, 2026 858 Views 0 comment Print

The case examined whether properties mortgaged with banks could be released from attachment. The Tribunal ruled that repayment of loans using illicit funds justified attachment to preserve assets for confiscation.

Appeals Partly Allowed as Namesake Partners Cleared for Lack of Control

January 6, 2026 324 Views 0 comment Print

The issue was whether statements and digital records from Customs probes could support FEMA action. The Tribunal ruled they are admissible and sufficient to establish illegal foreign exchange payments.

FEMA Contravention Proven, Relief Granted Due to Limited Role

January 6, 2026 453 Views 0 comment Print

The case examined whether penalty quantum should reflect the appellant’s role in the transaction. The Tribunal reduced the penalty after noting the dominant involvement of a third party and lack of comprehensive investigation.

Share Gain Addition Struck Down Because It Was Outside Reopening Scope

January 6, 2026 387 Views 0 comment Print

No on-money addition was made in the cases of other co-owners of the same property. The ITAT held that the Revenue cannot adopt a contradictory stand on identical facts.

Rule of Consistency Bars On-Money Addition Against One Co-Owner

January 6, 2026 672 Views 0 comment Print

The issue was whether a buyer could be taxed for alleged cash payment based only on the seller’s admission. The Tribunal ruled that in the absence of direct or corroborative evidence, no on-money addition can be sustained in the buyer’s hands.

₹4 Crore Addition Deleted Because Jurisdiction Collapsed Under Section 153C

January 6, 2026 405 Views 0 comment Print

The Tribunal ruled that the reassessment was time-barred because limitation was wrongly computed from the search date. The key takeaway is that receipt of seized material governs jurisdiction for non-searched persons.

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