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Loan Addition Deleted Because Amount Was Repaid in Same Year

January 5, 2026 729 Views 0 comment Print

The issue was whether a loan can be treated as unexplained despite full repayment within the year. The Tribunal held that once receipt and repayment are proved through banking channels, section 68 cannot apply.

Estimated Income Reduced Because Declared Profit Was Ignored

January 5, 2026 267 Views 0 comment Print

The issue was whether declared business income can be overlooked while estimating profits after rejecting books. The Tribunal held that ignoring returned income leads to double taxation and directed its set-off.

Share Capital Addition u/s 68 Fails in Pre-2013 Years: Kolkata ITAT Deletes ₹4.28 Cr

January 5, 2026 348 Views 0 comment Print

The issue was whether the company could be asked to explain the source of shareholders funds for a pre-2013 year. The Tribunal held that the proviso to section 68 is prospective, making the addition unsustainable.

Reassessment Quashed Because Notices Were Issued to a Dead Person

January 5, 2026 504 Views 0 comment Print

The issue was whether reassessment can continue when all notices are issued in the name of a deceased assessee. The Tribunal held such proceedings void ab initio, as jurisdiction ceases upon death.

Addition Restored for Violating Rule 46A Procedure

January 5, 2026 294 Views 0 comment Print

The issue was whether the appellate authority could delete a large unexplained investment without following Rule 46A. The Tribunal held that bypassing mandatory procedure invalidates the relief, and the matter must be re-examined.

Cash Addition Quashed for Wrong Section: 153C, Not 153A, Applicable

January 5, 2026 309 Views 0 comment Print

The issue was whether cash found at a third party’s premises could be added in the assessee’s 153A assessment. The Tribunal held such additions invalid, ruling that proceedings must be initiated under section 153C.

Reassessment Quashed for Breach of Proviso to Section 147

January 5, 2026 453 Views 0 comment Print

The issue was reopening beyond four years after a completed scrutiny assessment. The Tribunal held the reassessment invalid as there was no finding of failure to disclose material facts, a mandatory precondition under the proviso to section 147.

PF–ESI Disallowance Sustained Because Checkmate Services Applies Retrospectively

January 5, 2026 1128 Views 0 comment Print

The issue was whether delayed employees’ PF/ESI contributions paid before filing the return could be allowed. The Tribunal held that the Supreme Court’s interpretation in Checkmate Services is declaratory and applies to earlier years, mandating disallowance.

Section 36(1)(viii) Deduction Allowed for Renewable Energy Financing Business

January 5, 2026 525 Views 0 comment Print

The issue was whether long-term financing income qualified for deduction despite reclassification of receipts. The Tribunal held the entity eligible, citing statutory changes, past approvals, and consistency across years.

Entire Purchase Addition Quashed for Exceeding Appellate Jurisdiction

January 5, 2026 516 Views 0 comment Print

The issue was whether the appellate authority could enhance income by adding entire purchases when the AO had only made a small commission addition. The Tribunal held that such enhancement, without fresh material and beyond the subject matter of appeal, is illegal.

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