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Delhi HC Confirms Concurrent Jurisdiction of JAO and FAO for Section 148 Proceedings

October 6, 2025 1026 Views 0 comment Print

Reiterating its view from K.S. Builders Pvt. Ltd., the Delhi HC held that both Jurisdictional and Faceless Assessing Officers have concurrent powers to issue reassessment notices under Section 148 of the Income Tax Act.

No Exclusive Right for Faceless AO: Delhi HC Reiterates Dual Jurisdiction Under Section 148

October 6, 2025 705 Views 0 comment Print

Delhi High Court’s ruling in Neena Wadhwa v. PCIT upholds the concurrent power of both the Jurisdictional Assessing Officer (JAO) and the Faceless Assessing Officer (FAO) to issue reassessment notices under Section 148, citing the binding precedent of T.K.S. Builders Pvt. Ltd..

ITAT Hyderabad Deletes CPC Adjustments – Double Disallowance & Wrong 43B Addition Quashed

October 4, 2025 762 Views 0 comment Print

ITAT Hyderabad deletes CPC adjustments for Caspian Impact Investments. Quashes double disallowance of Section 37(1) loss and Section 43B addition on transferred, carried-forward liability.

No addition for Medical College Donation Based Solely on Third-Party Evidence

October 4, 2025 546 Views 0 comment Print

Hyderabad ITAT quashes ₹20.50 lakh tax addition based on medical college search documents. Rules third-party material needs corroboration and cross-examination.

Belated Payment of Tribunal Cost Not Fatal to Appeal: ITAT Hyderabad

October 4, 2025 585 Views 0 comment Print

ITAT Hyderabad restores appeal dismissed by CIT(A) due to late payment of Tribunal-directed cost. Rules substantive justice prevails, imposes additional ₹20,000 fine.

CIT(A) Cannot Remand 143(3)/144B Assessments Under New 251(1) Proviso: ITAT Pune

October 4, 2025 2688 Views 0 comment Print

Pune ITAT rules CIT(A) wrongly applied new S. 251(1) proviso to remand a scrutiny assessment, which only applies to S. 144 orders. CIT(A) directed to decide the appeal on merits.

ITAT Pune Rules Land Sold to Developer as Rural Agricultural Land, Deletes ₹2.74 Cr Addition

October 4, 2025 885 Views 0 comment Print

Pune ITAT deletes ₹2.74 Cr capital gains addition on land sale, ruling it was rural agricultural land exempt u/s 2(14). Followed precedent set in spouse’s identical case.

Secured vs Unsecured Loans Not Comparable – Interest Paid to Relatives at 15% Allowed

October 4, 2025 981 Views 0 comment Print

Tribunal holds that reasonableness under Section 40A(2)(b) must be benchmarked against prevailing market rates for unsecured loans, not against lower-risk secured bank rates.

Past Acceptance No Defence in 263 – Tribunal Says Tax Depreciation Must Follow Act

October 4, 2025 366 Views 0 comment Print

ITAT Ahmedabad upholds PCIT’s Section 263 order, ruling that tax depreciation must comply with Explanation 10 to Section 43(1) and ICDS-VII. Unadjusted Government grants must reduce WDV, regardless of prior acceptance.

ITAT Delhi Deletes ₹13 Lakh Cash Deposit Addition Linked to Sale of Rural Agricultural Land

October 4, 2025 1335 Views 0 comment Print

ITAT Delhi ruled on the unexplained cash deposit addition in Jitendra Singh Vs ITO (AY 2015-16). The Tribunal accepted the assessee’s explanation that the Rs.13

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