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Delayed Filing Blocks 80P Deduction: ITAT Upholds CPC Adjustment

December 23, 2025 834 Views 0 comment Print

ITAT Bangalore rules that Section 80P deductions cannot be claimed if the return is filed after the due date. The decision reinforces compliance with Section 80AC(ii) and aligns with Madras HC precedent.

No Hearing, No Finality: ITAT Restores 69 Addition in Reassessment to AO

December 23, 2025 510 Views 0 comment Print

ITAT Bangalore directs reassessment with full hearing for an agriculturist after procedural lapses in notices and missed hearings. The ruling emphasizes the importance of fair opportunity under Sections 148 and 144B.

Section 68 Addition Cannot Be Taxed Twice, ITAT Directs Netting Off from Business Receipts

December 23, 2025 978 Views 0 comment Print

ITAT Visakhapatnam held that unexplained cash credit under Section 68 must be netted off against business income to prevent double addition. The ruling ensures accurate assessment and fair taxation.

Failure to Prove Cash Source Justifies Addition Under Section 69A: ITAT Hyderabad

December 23, 2025 711 Views 0 comment Print

Cash deposits were rightly taxed as unexplained money when the assessee failed to discharge the primary burden of proof. Absence of contemporaneous evidence defeats claims of redeposit of cash.

Section 153(3)(ii) Prevails Over Section 153(2A) in Special Audit Cases: ITAT Lucknow

December 23, 2025 387 Views 0 comment Print

The ruling clarifies that Section 153(3)(ii) operates as an exception to the normal limitation framework. When assessments are made to give effect to appellate directions involving special audits, no fixed time limit applies.

Bhagavad Gita, Vedanta & Yoga Are Philosophical and Not Religious: Madras HC

December 23, 2025 4713 Views 0 comment Print

The court held that valid registration under income-tax law is a relevant factor under FCRA and cannot be ignored. Failure to consider it violated Section 52, which makes FCRA supplementary to other laws.

Ex-parte Enhancement Without Notice Unsustainable: ITAT ITAT Bangalore

December 23, 2025 882 Views 0 comment Print

The Tribunal ruled that increasing assessed income without issuing a notice under section 251 violates natural justice. The case was remanded as ex-parte enhancement beyond the original addition was found legally unsustainable.

CPC Cannot Deny Section 10(23C)(iiiad) Exemption via Section 143(1) Adjustments ITAT Bangalore

December 23, 2025 1026 Views 0 comment Print

Tribunal held that debatable issues fall outside scope of summary adjustments under section 143(1). Denial of exemption based on procedural lapses was therefore unsustainable.

ITAT Bangalore: Section 148 Valid, Reassessment Set Aside for Non-Supply of Reasons

December 23, 2025 741 Views 0 comment Print

ITAT Bangalore invalidated a reassessment where the assessee was not provided the recorded reasons, emphasizing that reopening notices must be supported by clear, communicated reasons before filing returns.

Later-Year Depreciation Cannot Be Decided Until Base Year Cost Is Finalised: ITAT Bangalore

December 23, 2025 354 Views 0 comment Print

The Tribunal ruled that depreciation for subsequent years is consequential to the first-year determination of actual cost. Appeals were restored as the base year issue remained undecided.

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