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Books Not Produced Earlier – Section 145(3) Rejection Restored for Fresh Verification

December 10, 2025 459 Views 0 comment Print

ITAT Agra restored AO’s 145(3) rejection and additions under sections 68 & 41(1) for re-verification, directing assessee to produce complete books and supporting documents. The matter requires factual verification to ensure substantial justice.

Repayment Proves Genuineness – Unsecured Loans Accepted, Addition Removed

December 10, 2025 363 Views 0 comment Print

ITAT Pune deletes Rs.17.90L addition u/s 68 as LLP proved genuineness, identity & repayment of unsecured loans; appeal allowed in full.

LTCG on JDA Year Reopened: Tribunal Sends Case Back for Proper Verification

December 10, 2025 144 Views 0 comment Print

ITAT Pune restored LTCG issue for AY 2015-16 to CIT(A)/NFAC, directing assessee to submit cost details & evidences, ensuring proper verification and fair adjudication.

ITAT Dismisses Rs. 24 Crore Additions Over Third-Party Documents

December 10, 2025 465 Views 0 comment Print

Additions based on decoded entries from a third-party cash book were struck down, as they did not align with the assessee’s audited books or bank statements, reinforcing the ‘dumb document’ principle.

Penalty Deleted After ITAT Quashes Quantum Addition

December 9, 2025 1077 Views 0 comment Print

The ITAT held that a penalty under section 271(1)(c) cannot survive once the underlying quantum addition is deleted by a binding ITAT order. The Revenue’s appeal was dismissed as no stay or direction from the High Court could revive the deleted quantum.

Invalid Notice, Wrong Remand Report & PAN Errors: ITAT Orders Fresh Assessment

December 9, 2025 285 Views 0 comment Print

ITAT rules that reliance on remand report from a different year is invalid, restoring matter to Assessing Officer for AY 2012-13.

Seized Papers Showing Cash Payment Treated as Credible Evidence

December 9, 2025 474 Views 0 comment Print

Detailed seized agreement and subsequent sale deed considered strong corroboration. Addition under Section 69A sustained in search-based reassessment.

ITAT Clarifies: Working Capital Adjustment May Nullify Interest Addition

December 9, 2025 549 Views 0 comment Print

Tribunal holds that working capital impact must be examined by the TPO when comparables are selected by the Department. If adjustment is granted, no separate interest addition is warranted.

Disallowance Invalid as Negative Capital Stemmed from Non-Cash Adjustment

December 9, 2025 429 Views 0 comment Print

The Tribunal ruled that interest could not be disallowed when ample interest-free funds existed and no link was shown between overdraft borrowings and partners’ drawings. The key takeaway is that presumption of utilisation of own funds applies when mixed funds are available.

Tribunal Rejects Reopening Triggered by Irrelevant Information

December 9, 2025 330 Views 0 comment Print

The Tribunal held that reassessment could not stand because the recorded reasons pertained to a different assessment year. The reopening was invalid, and all related additions were rendered infructuous.

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