Follow Us:

Third-Party Statement Alone Insufficient to Treat Loan as Bogus

December 29, 2025 546 Views 0 comment Print

The issue was whether unsecured loan additions under section 68 could survive based solely on investigation reports and third-party statements. ITAT held that without independent enquiry and nexus to seized material, such additions are unsustainable.

Big Dividend, Real Costs: ITAT Upholds Rule 8D Disallowance

December 29, 2025 243 Views 0 comment Print

The ITAT held that earning significant exempt dividend income necessarily involves indirect administrative expenses. In the absence of separate books, the AO rightly applied Rule 8D to compute disallowance.

Genuine Member Cash Transactions Protected by Reasonable Cause Rule

December 29, 2025 555 Views 0 comment Print

The issue was whether penalties under sections 271D and 271E apply to cash dealings of a credit society with its members. ITAT held that genuine, audited member transactions supported by reasonable cause are protected under section 273B.

Pre-Demonetisation Withdrawals Can Explain Post-Ban Cash Deposits

December 29, 2025 459 Views 0 comment Print

The issue was whether demonetisation-era deposits could be taxed despite admitted prior withdrawals. ITAT held that when withdrawals are genuine and the occasion is real, section 69A cannot be applied on presumptions.

Approval for One Issue, Reopening for Another Is Legally Fatal

December 29, 2025 366 Views 0 comment Print

The ITAT ruled that section 151 approval must strictly correspond to the recorded reasons for reopening. Any factual inconsistency reflects non-application of mind and collapses the reassessment at inception.

Mechanical Revenue Objections Rejected on Section 14A and MAT

December 29, 2025 318 Views 0 comment Print

The Tribunal held that no disallowance under Section 14A is warranted when exempt dividend arises incidentally from shares held as stock-in-trade in banking business. Applying Supreme Court precedents, it deleted the entire sustained disallowance, reaffirming that such income does not trigger Section 14A.

Commission @0.15% Reflects True Income in Entry Operations

December 29, 2025 597 Views 0 comment Print

The AO taxed entire bank credits despite accepting the assessee as an entry operator. ITAT ruled that fund rotations cannot be treated as unexplained once the nature of business is admitted.

Allotment Date Governs Stamp Value Under Section 56(2)(x)

December 29, 2025 492 Views 0 comment Print

ITAT ruled that an allotment letter constitutes a valid agreement for section 56(2)(x) where consideration and binding terms are recorded. Stamp duty value on the allotment date, not the delayed registration date, must be applied.

ITAT Grants Fresh Opportunity to Claim Section 54F Deduction

December 29, 2025 294 Views 0 comment Print

ITAT remanded a ₹2.90 crore s.54F deduction case, allowing the assessee to furnish complete documentation and have the claim re-examined on merit.

Transfer Pricing Adjustment Softened for Long-Standing ECB Loans

December 29, 2025 603 Views 0 comment Print

ITAT acknowledged that ECB interest was fixed and consistently accepted in earlier years but adopted a marginally revised rate after the assessee’s voluntary settlement to close the dispute.

Search Post by Date
July 2026
M T W T F S S
 12345
6789101112
13141516171819
20212223242526
2728293031