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Cash Deposits Alone Cannot Justify Reopening of Assessment: ITAT Delhi

December 23, 2025 924 Views 0 comment Print

The Tribunal struck down reopening where reasons conflicted and rested solely on AIR cash-deposit data. The key takeaway is that reassessment needs a clear, reasoned nexus.

Section 144C Can’t Extend Limitation: TP Assessment Quashed as Time-Barred

December 22, 2025 486 Views 0 comment Print

The dispute centered on whether DRP directions allow completion of assessment beyond statutory time limits. The Tribunal clarified that section 144C does not create an independent limitation period. Procedural timelines cannot defeat the mandatory bar under section 153.

No Forfeiture, No Tax: Advance Can’t Be Income Under Section 56

December 22, 2025 7017 Views 0 comment Print

The issue was whether advance money from a failed land deal could be taxed as income. The Tribunal held that without clear forfeiture, section 56(2)(ix) does not apply. Key takeaway: forfeiture is mandatory to tax advances.

No Nexus, No Big Section 14A Hit: Disallowance Slashed to ₹10 Lakh

December 22, 2025 258 Views 0 comment Print

The issue was whether a ₹3.05 crore disallowance under section 14A could stand without nexus to exempt income. The ITAT held that only a reasonable amount with clear linkage can be disallowed, capping it at ₹10 lakh.

One Satisfaction Note for Seven Years Invalidates Section 153C: ITAT Pune

December 22, 2025 423 Views 0 comment Print

The issue was whether section 153C could extend beyond six years without discovery of an undisclosed asset of ₹50 lakh or more. The ITAT held that in absence of such asset-based satisfaction, extended jurisdiction is invalid.

Same-Day Cash Withdrawal and Deposit Not Unexplained Income

December 22, 2025 591 Views 0 comment Print

The ITAT held that cash redeposited after a clearly documented bank withdrawal cannot be treated as unexplained. The ruling emphasizes that verifiable fund movement defeats section 69A additions.

FMV Claim Rejected Because No Error Shown in Valuation Methodology

December 22, 2025 228 Views 0 comment Print

The ITAT held that land-levelling and fencing expenses are integral to acquiring agricultural land and qualify for section 54B deduction. The ruling clarifies what constitutes eligible investment despite restricting unregistered costs.

Section 263 Revision Upheld as AO Taxed Only TDS Credit Instead of Undisclosed Commission

December 22, 2025 201 Views 0 comment Print

The ITAT held that taxing only TDS credit, while leaving the underlying undisclosed commission untaxed, is a patent error. Section 263 revision was rightly invoked to protect revenue.

Section 263 Revision Quashed for Substituting PCIT’s Opinion Over AO’s Due Inquiry

December 22, 2025 219 Views 0 comment Print

The issue was whether revision under section 263 could be invoked to deny 80P deduction on interest from co-operative bank deposits. The ITAT held that such revision is invalid when the AO has taken a legally settled and permissible view.

Section 292BB Can’t Cure Missing 143(2) Notice: ITAT Hyderabad

December 22, 2025 360 Views 0 comment Print

Hyderabad ITAT held that even a delayed return filed during assessment is valid, and absence of mandatory Section 143(2) notice renders the entire assessment void.

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