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Crypto Loan Interest = Cost of Acquisition; Deduction Allowed Despite Section 115BBH

February 6, 2026 801 Views 0 comment Print

The dispute examined whether loan interest used to buy virtual digital assets could be deducted. The ruling held that such interest forms part of cost of acquisition and is allowable despite Section 115BBH restrictions.

143(1) Adjustment Without Prior Intimation Invalid; CPC Action Quashed

February 6, 2026 768 Views 0 comment Print

The tribunal held that any adjustment while processing a return under Section 143(1) requires prior intimation to the assessee. Disallowance made without issuing such notice is invalid in law.

Golden Harvest Scheme Discount ≠ Interest; No TDS U/s 194A, 201 Default Quashed

February 6, 2026 378 Views 0 comment Print

ITAT Lucknow ruled that Golden Harvest Scheme benefit is a sales discount, not interest u/s 2(28A); hence no TDS u/s 194A applies and 201(1)/(1A) demand was quashed.

Commission Agent Theory Accepted; Entire Bank Credits Not Taxable U/s 68

February 6, 2026 600 Views 0 comment Print

The tribunal held that large cash deposits in bank accounts cannot be taxed as unexplained income when the assessee proves he acted only as a commission agent. Only commission income, and not gross deposits, is taxable in such cases.

Repayment of Own Deposit ≠ Deemed Dividend; 2(22)(e) Not Attracted

February 6, 2026 306 Views 0 comment Print

ITAT Ahmedabad held that repayment of a shareholder’s own deposit, even if used for political donation, is not deemed dividend u/s 2(22)(e) as no company funds were advanced.

Section 249(4)(b) Dismissal Reversed; One Opportunity to Explain Advance-Tax Liability

February 6, 2026 297 Views 0 comment Print

The issue was dismissal of appeals for non-payment of admitted tax without hearing on merits. The Tribunal restored the appeals, holding that the assessee deserved an opportunity to explain advance tax liability.

Third-Party DD Payment Explains Investment; U/s 69 Addition Deleted

February 6, 2026 252 Views 0 comment Print

The ITAT ruled that once the assessee establishes the source of investment, addition for unexplained investment cannot survive. Direct payment by a financier through demand draft explained the transaction.

Scrutiny Valid Despite Section 12A Rejection; Merits Restored Pending Registration Outcome

February 6, 2026 288 Views 0 comment Print

The case examined taxation of a charitable entity when registration under Section 12A was unsettled. While scrutiny selection was upheld, the assessment was remanded to await the outcome of registration proceedings.

Section 50C Date Shift Allowed; Stamp Value to Be Taken as on Agreement Date

February 6, 2026 303 Views 0 comment Print

Authorities applied a higher stamp value at registration to compute capital gains. The Tribunal corrected this by directing consideration of the stamp value on the agreement date, subject to verification.

Section 80P(2)(d) Allowed; Interest from Co-op Banks Fully Deductible

February 6, 2026 366 Views 0 comment Print

The tribunal set aside the disallowance of deduction on interest earned from cooperative bank deposits. Consistent judicial precedents confirm eligibility under Section 80P(2)(d).

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