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Section 275(1)(c) Limitation Runs From AO’s Initiation, Not JCIT/Addl. CIT Notice

August 23, 2025 1113 Views 0 comment Print

Delhi High Court ruled that a penalty under Section 271E was time-barred, clarifying that limitation period begins with Assessing Officer’s initiation.

Retrospective Amendment Cannot Invite Section 270A Penalty: ITAT Ahmedabad

August 23, 2025 981 Views 0 comment Print

Ahmedabad ITAT deletes a penalty under Section 270A for a deduction on education cess. The court ruled the claim was bona fide and not a case of misreporting.

Borrowed Satisfaction Not Valid for Reopening, ITAT Deletes ₹5.21 Cr Addition

August 23, 2025 510 Views 0 comment Print

The ITAT Ahmedabad has deleted a Rs.5.21 crore addition to income, ruling that the reassessment was invalid due to a lack of independent verification of the evidence.

CIT(A) Cannot Change or reverse his Decision Under Garb of Rectification

August 23, 2025 954 Views 0 comment Print

ITAT Jodhpur quashes a rectification order, ruling a CIT(A) cannot change a decision under the guise of rectifying a mistake apparent from the record.

Not Length but Cause of Delay Matters – 353-Day Delay Condoned

August 23, 2025 516 Views 0 comment Print

The ITAT Bangalore has condoned a 353-day appeal delay and set aside an ex parte order, emphasizing that the cause of the delay matters more than its length.

CPC cannot deny Section 80P deduction on belated return prior to AY 2021-22

August 23, 2025 762 Views 0 comment Print

ITAT Jodhpur rules that the CPC cannot deny an 80P deduction on belated returns for assessment years before 2021-22, as it lacked the authority under Section 143(1).

Grey Market Sourcing? Entire Bogus Purchases Can’t Be Disallowed

August 23, 2025 1212 Views 0 comment Print

ITAT Mumbai has ruled that when sales are genuine but purchases are bogus, only the embedded profit, typically 3%, should be added to income. The tribunal dismissed a revenue appeal, confirming the principle that entire bogus purchases cannot be disallowed.

Mere Disallowance of Interest Claim Doesn’t Warrant Penalty u/s 271(1)(c)

August 23, 2025 510 Views 0 comment Print

The Mumbai ITAT quashed a penalty under section 271(1)(c) against Ideal Energy Projects, citing that merely claiming a deduction is not furnishing inaccurate particulars.

TDS Delay After 01.06.2015 Attracts Mandatory 234E Late Fee: ITAT Mumbai

August 23, 2025 339 Views 0 comment Print

Mumbai ITAT rules that late fees under Section 234E are applicable for delayed TDS statement filings that occurred after June 1, 2015, upholding a Rs. 85,200 penalty.

Accrued Interest in Loan Acquisition is Purchase Consideration, No TDS: ITAT Mumbai

August 23, 2025 855 Views 0 comment Print

The ITAT Mumbai ruled that accrued interest in a loan sale is part of the purchase consideration, not interest. This means a borrower-lender relationship doesn’t exist, and TDS is not required.

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