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No Fresh U/s 143(2) Needed After Section 263 – ITAT Reverses CIT(A) Revives Assessment

April 4, 2026 603 Views 0 comment Print

The tribunal reversed the CIT(A)’s decision for wrongly quashing assessment due to lack of notice under Section 143(2). It held that Section 263 proceedings are a continuation of original assessment.

Section 80P Deduction Allowed on Bank Interest – ITAT Follows Tumkur Merchants, Distinguishes Totagars

April 3, 2026 900 Views 0 comment Print

The ruling holds that deposits made from surplus business funds are part of operational activity. Interest earned on such deposits is business income and not income from other sources. Therefore, Section 80P benefit was granted.

Ex-Parte Succession Certificate Set Aside – SC Protects Minor’s Rights, Allows Fresh Hearing

April 3, 2026 444 Views 0 comment Print

The issue was whether a succession certificate granted without impleading a minor heir was valid. The Supreme Court set aside the ex parte order, holding denial of hearing to a minor vitiates proceedings.

Penalty Deleted as Issue Becomes Debatable – HC Admission of Quantum Appeal Saves Assessee

April 3, 2026 528 Views 0 comment Print

The case examines whether penalty can be levied when the quantum issue is admitted by the High Court. The Tribunal held that admission of substantial questions of law makes the issue debatable. As a result, penalty under Section 271(1)(c) was rightly deleted.

Fresh Claim of Section 54F Cannot Be Rejected Mechanically – ITAT Remands for Reconsideration

April 3, 2026 582 Views 0 comment Print

The issue was denial of deduction under Section 54F as a fresh claim not made in return. The ruling remanded the matter, holding such claims can be examined if supported by facts.

Entire Bank Deposits Can’t Be Taxed U/s 69A – Only Reasonable Commission Income Taxable

April 3, 2026 453 Views 0 comment Print

The issue was whether full bank deposits of a commission agent can be taxed as unexplained income. The ruling held only commission income taxable, with 8% estimation upheld as reasonable.

Reassessment Beyond 3 Years Invalid if Escaped Income Below ₹50 Lakh: ITAT Chennai

April 3, 2026 966 Views 0 comment Print

The issue was whether reassessment beyond 3 years is valid when escaped income is below ₹50 lakh. The ruling held such notice invalid under Section 149, and the key takeaway is strict adherence to limitation rules.

Redeployment of Withdrawn Cash Cannot Trigger Section 68 Addition: Source Proven

April 3, 2026 426 Views 0 comment Print

The Tribunal examined whether cash deposits backed by prior withdrawals can be taxed as unexplained income. It ruled that in absence of evidence showing alternative use of cash, the source stands explained.

Demonetisation Cash Sales Accepted: No U/s 68 Addition Without Proof of Bogus Sales

April 3, 2026 399 Views 0 comment Print

The Tribunal examined whether demonetisation cash deposits linked to recorded business sales could be taxed as unexplained income. It ruled that once the source is established through books, addition under Section 68 is unsustainable.

Vague Penalty Notice Invalid: ITAT Deletes 200% Penalty Under Section 270A

April 3, 2026 417 Views 0 comment Print

The Tribunal ruled that failure to specify underreporting or misreporting in notice invalidates penalty. Proper identification of charge is mandatory for valid proceedings.

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