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Reopening on Wrong Reason Quashed: ITAT Deletes Section 68 Addition

December 1, 2025 927 Views 0 comment Print

ITAT ruled that reopening was bad in law as reasons cited property purchases, while additions related to cash credits—showing no live nexus. The case reaffirms that reassessment must be based on specific, relevant material.

ITAT Rules Exemption Cannot Be Denied for Curable Form 10B Defect

December 1, 2025 684 Views 0 comment Print

Delhi ITAT held that non-filing of Form 10B is a curable defect and the assessee must be given an opportunity under section 139(9). Gross receipts cannot be taxed in entirety if exemptions fail.

Demonetisation Cash Deposits Not Unexplained: ₹45 Lakh Addition Deleted

December 1, 2025 714 Views 0 comment Print

The ITAT held that cash deposits recorded in books and from legitimate business sales during demonetisation cannot be treated as unexplained under Section 69A. Entire addition of ₹45.23 lakh was quashed.

TP Adjustment Under 80IA(10) Dismissed for Lack of Evidence

December 1, 2025 384 Views 0 comment Print

The Delhi ITAT upheld deletion of ₹2.57 crore TP adjustment, confirming that mere margin variations do not trigger 80IA(10) without evidence of profit manipulation. Revenue’s appeal dismissed.

Farmhouse Qualifies as Residential House: Delhi ITAT Upholds Section 54F Relief

November 30, 2025 6150 Views 0 comment Print

The tribunal dismissed the revenue’s appeal, holding that the assessee was entitled to ₹2.36 crore deduction under Section 54F. Evidence showed only one residential property purchase, and farmhouse classification did not disqualify the claim.

AO’s Suspicion Not Evidence: Section 68 not Apply to Opening Balances

November 30, 2025 1293 Views 0 comment Print

Commission payments to agents were held genuine for AY 2013-14 and 2014-15. Tribunal directed deletion of disallowances as payments were backed by bank records, TDS, and recipient confirmations.

Bogus Purchases: Only 6% Profit Element Taxable: Delhi ITAT

November 30, 2025 1959 Views 0 comment Print

Delhi ITAT upholds CIT(A) order, ruling that only profit embedded in alleged bogus purchases can be taxed, not the full purchase value.

Satisfaction Note of 24.05.2021 Shifts Search-Year: ITAT Holds AY 2011-12 Outside Six-Year Block

November 30, 2025 483 Views 0 comment Print

ITAT Delhi held that AY 2011-12 is barred by limitation under Section 153C as the deemed search year started only when documents were received in 2021, nullifying the reassessment and related penalties.

Lack of Board Affiliation Not a Barrier: ITAT Remands Section 12A Application

November 30, 2025 774 Views 0 comment Print

ITAT Delhi held that operating a primary school itself constitutes “education,” removing the need for CBSE or DOE affiliation for 12A registration under the Income Tax Act.

Genuine Misunderstanding of VRS Exemption Not “Under-Reporting”

November 29, 2025 819 Views 0 comment Print

The Tribunal emphasized that an error regarding VRS exemption made by a salaried, non-technical taxpayer cannot be classified as deliberate under-reporting. With no false claim or suppression, the 270A penalty was deleted.

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