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Ten-Year Section 153A Block to Be Counted from AY of Search Year, Not Before

November 9, 2025 585 Views 0 comment Print

ITAT Delhi held that reassessment for AY 2010-11 was invalid since it exceeded the ten-year limitation from the search year. The notice was declared time-barred and issued without jurisdiction.

Section 153C Notice Beyond Six-Year Block Period Held Invalid: ITAT Delhi

November 9, 2025 435 Views 0 comment Print

TAT Delhi held that a 153C assessment for AY 2012–13 was invalid, as the six-year block must be counted from date of satisfaction recorded by AO of non-searched person.

Section 153C Block Period to Be Counted from Date of Receipt of Seized Material, Not Search Date

November 9, 2025 477 Views 0 comment Print

ITAT Delhi held that ten-year block under Section 153C must be computed from date AO of non-searched person receives seized material, not search date.

₹1.48 Cr Jewellery Addition Deleted as Declared Holdings Exceeded Search Findings

November 9, 2025 789 Views 0 comment Print

ITAT held that no addition under Section 69A was justified when the jewellery found during search was less than the amount already declared in wealth tax returns. Revenue’s appeal was dismissed.

No TDS Liability on Year-End Provisions Without Identified Payees: ITAT Mumbai

November 9, 2025 1386 Views 0 comment Print

ITAT Mumbai held that TDS need not be deducted on year-end expense provisions where payees are unidentifiable and liability crystallizes later. Case remanded for factual verification.

ITAT Delhi Deletes Double Addition of ₹14.45 Crore Made by CPC

November 9, 2025 786 Views 0 comment Print

ITAT held that once income is accounted in the Profit & Loss statement, further addition by the tax authority is unlawful. The order restores the correct claim of losses and eliminates double addition.

No Addition if Loan Identity & Creditworthiness Proven; Section 115BBE Applies Prospectively

November 9, 2025 645 Views 0 comment Print

ITAT Delhi upheld deletion of additions under Section 68 after the assessee proved identity, creditworthiness, and genuineness of lenders. Interest disallowance was also deleted as loans were repaid and taxed transactions verified.

Assessments Beyond Ten-Year Block Invalid Under Section 153C: ITAT Delhi

November 9, 2025 519 Views 0 comment Print

ITAT Delhi held that assessments for A.Ys 2011–12 and 2012–13 were invalid since they fell outside the ten-year block reckoned from the date of receipt of seized material. The Tribunal followed CIT v. Jasjit Singh (SC) and Ojjus Medicare (Del HC) rulings.

Valuer’s Report Ignored: ITAT Sends Case Back for Fair Market Re-Computation 

November 9, 2025 828 Views 0 comment Print

The ITAT held that the Assessing Officer cannot discard a registered valuer’s report without referring the matter to a Departmental Valuation Officer. The AO’s addition was set aside, and the fair market value must be recomputed based on the valuer’s report.

Kerala HC Stays Recovery Against Trust Pending Appeal After 12A Registration Restored

November 8, 2025 285 Views 0 comment Print

The Kerala High Court stayed tax recovery against an association, ruling that the NFAC must decide the pending appeal in light of the assessee’s restored Section 12A registration. The assessment order was based on the premise of cancellation, which the ITAT had since set aside.

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