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Section 69A Addition Upheld Because Assessee Failed to Explain Source of ₹7.5 Cr Cash: ITAT Delhi

May 15, 2026 333 Views 0 comment Print

ITAT Delhi restored a Section 69A addition after holding that the assessee failed to produce evidence supporting its claim that the seized cash was meant for inter-branch transfer. The Tribunal found the explanation unsupported and inconsistent with available records.

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

May 15, 2026 303 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 Delhi Deletes Capital Addition as No Liability Cessation Was Proved

May 15, 2026 318 Views 0 comment Print

ITAT Delhi held that addition under Section 41(1) cannot be made without proving cessation of liability. The Tribunal found that family loans continued to remain payable and were merely reclassified in the capital account.

Third-Party Loose Papers Cannot Justify Addition Without Cross-Examination: ITAT Delhi

May 15, 2026 636 Views 0 comment Print

ITAT Delhi ruled that reassessment in search cases requires prior approval under section 148B before passing the order. Since the department failed to obtain the prescribed approval, the assessment was quashed as invalid in law.

Section 56(2)(x) not Apply to Redevelopment Flats as Transaction Is Exchange of Existing Rights

May 15, 2026 579 Views 0 comment Print

The ITAT Mumbai held that receipt of a new flat in exchange for surrender of an old flat under a redevelopment arrangement does not amount to receipt of immovable property for inadequate consideration. The addition under Section 56(2)(x) was therefore deleted.

Assessment Quashed as Returned Income Exceeded Monetary Limits of ITO Jurisdiction

May 15, 2026 579 Views 0 comment Print

The ITAT Delhi held that scrutiny notice issued by an ITO lacking pecuniary jurisdiction rendered the entire assessment void ab initio. The Tribunal relied on CBDT Instruction No.1/2011 and judicial precedents on jurisdictional defects.

ITAT Surat Upholds Bogus LTCG Addition on Sunrise Asian Penny Stock, Applies ‘Human Probability’ Test

May 15, 2026 597 Views 0 comment Print

The ITAT Surat held that abnormal price rise in a penny stock and surrounding circumstances justified treating claimed LTCG as unexplained income under Section 68. The Tribunal found the transactions to be part of a pre-arranged accommodation entry scheme.

Notional Rent from Sister Concerns Taxable as ‘Other Sources’: ITAT Mumbai

May 15, 2026 351 Views 0 comment Print

The ITAT Mumbai held that notional rent cannot be taxed under “Income from Other Sources” without evidence that such income was actually received or receivable. The Tribunal deleted additions relating to shared premises with group companies.

ITAT rejected TPO’s recharacterisation of Boeing India as Full-Risk entity in technical services arrangement

May 15, 2026 318 Views 0 comment Print

 Transfer Pricing Officer (TPO) had wrongly recharacterised Boeing India Defense Private Limited as a full-risk service provider despite the Associated Enterprise (AE) assuming the entire contractual and operational risks relating to defence support services rendered to the Indian Air Force (IAF).

Section 80GGC Deduction Denied Due to Suspicious Political Donation

May 15, 2026 1617 Views 0 comment Print

The Tribunal upheld disallowance of deduction under Section 80GGC after finding the political donation lacked genuineness. The ruling highlights that payments through banking channels alone cannot establish a valid deduction when surrounding facts indicate accommodation entries.

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