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DCF Valuation Cannot Be Rejected Using Hindsight – ITAT Deletes ₹36.54 Crore Section 56(2)(viib) Addition

May 16, 2026 303 Views 0 comment Print

ITAT Mumbai ruled that replacing projected cash flows with actual profits while applying the DCF method is legally impermissible. The decision reaffirmed that DCF valuation is inherently based on future estimates and business expectations.

Section 68 Addition Crashes – ITAT Mumbai Says Suspicion & Investigation Wing Reports Cannot Replace Evidence

May 16, 2026 258 Views 0 comment Print

ITAT Mumbai held that additions under section 68 cannot survive where the Assessing Officer failed to conduct independent verification of alleged accommodation entries. Reliance solely on third-party investigation reports was rejected.

Agricultural Land Also Covered by Section 56(2)(x) – ITAT Upholds Addition Based on DVO Valuation

May 16, 2026 729 Views 0 comment Print

The Tribunal upheld tax addition where agricultural land was acquired below stamp duty valuation and DVO-determined fair market value. It ruled that agricultural status of land does not exclude applicability of section 56(2)(x).

ITAT Deletes Bogus Purchase Addition as No Evidence Linked Assessee to Alleged Accommodation Entries

May 15, 2026 1443 Views 0 comment Print

ITAT Ahmedabad held that reassessment under Section 147 was invalid as the Assessing Officer failed to show independent application of mind or establish a nexus between investigation material and escaped income.

ITAT Deletes Demonetization Cash Deposit Addition as Sales Were Recorded in Books

May 15, 2026 582 Views 0 comment Print

ITAT Chandigarh held that cash deposits during demonetization could not be treated as unexplained income since the amounts were recorded as sales turnover in the books and supported by VAT returns.

ITAT Quashes Section 263 Revision as AO Conducted Detailed Inquiry into Agricultural Income

May 15, 2026 402 Views 0 comment Print

ITAT Rajkot held that revision under section 263 was not sustainable where the Assessing Officer had already conducted extensive verification of agricultural income and expenses. The Tribunal observed that detailed notices, documentary evidence, and independent inquiries were part of the original assessment proceedings.

ITAT Grants Section 12AB Registration as Missing PAN Details Cannot Make Small Donations Non-Genuine

May 15, 2026 507 Views 0 comment Print

ITAT Nagpur held that nominal donations received in small amounts could not be treated as non-voluntary contributions merely because PAN or full address details of donors were unavailable. The Tribunal found no adverse evidence questioning the genuineness of donations or activities.

No Section 56 Addition as Property Value Difference Was Within 10% Tolerance Band

May 15, 2026 426 Views 0 comment Print

ITAT Mumbai deleted the addition under Section 56(2)(vii)(b) after holding that a 2.3% variation between agreement value and stamp duty value fell within the permissible tolerance band applicable retrospectively.

Agricultural Land Cannot Be Treated as Capital Asset Due to Subsequent Commercial Use by Purchaser: ITAT Hyderabad

May 15, 2026 498 Views 0 comment Print

ITAT Hyderabad held that rural agricultural land situated beyond 8 kilometres from municipal limits cannot be taxed as a capital asset merely because the purchaser later used it for commercial plotting. The Tribunal ruled that future use by the buyer does not alter the land’s character in the seller’s hands.

Share Premium Received Through Verified Investors Cannot Be Treated as Bogus Cash Credit: ITAT Delhi

May 15, 2026 321 Views 0 comment Print

ITAT Delhi deleted a ₹45 lakh addition under Section 68 after finding that the assessee had furnished complete details of investor companies and share allotment. The Tribunal held that verified share application money could not be treated as unexplained cash credit.

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