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Charitable Trust as Pass-Through Entity: ITAT Deletes Interest Disallowance Rejects 8% Profit Estimation

April 27, 2026 231 Views 0 comment Print

The Tribunal held that interest expenses cannot be disallowed when the trust merely facilitates transactions and costs are reimbursed. It emphasized the concept of real income and pass-through structure.

Security Deposits from Contractors Not Cash Credits: ITAT Upholds Deletion of ₹22.61 Cr Addition

April 27, 2026 306 Views 0 comment Print

The issue was whether contractor deposits could be treated as unexplained credits. The Tribunal held they were genuine trade liabilities, not taxable under Section 68.

Reopening Quashed – Incorrect Facts Cannot Extend Limitation Beyond 3 Years

April 27, 2026 504 Views 0 comment Print

The issue was reopening based on incorrect cash deposit figures exceeding ₹50 lakh. The Tribunal held actual amount was lower, making notice time-barred and invalid.

12.5% Profit on Bank Credits Excessive, Restricted to 4%: ITAT Hyderabad

April 27, 2026 273 Views 0 comment Print

ITAT Hyderabad holds 12.5% profit estimation on ₹2.52 crore bank credits excessive; rejects commission agent claim due to lack of evidence but restricts income estimation to 4%, granting partial relief to the assessee.

ITAT Allows 80P Deduction as Interest Earned from Co-Op Banks Treated as Eligible Income

April 27, 2026 507 Views 0 comment Print

The Tribunal held that interest earned from co-operative banks qualifies for deduction under Section 80P(2)(d). It clarified that co-operative banks are to be treated as co-operative societies. The ruling resolves disputes on eligibility of such income.

ITAT Allows Advertisement and Marketing Expenses Due to Revenue Nature Despite No Income

April 27, 2026 348 Views 0 comment Print

ITAT ruled that selling and distribution expenses cannot form part of work-in-progress. Such costs do not contribute to inventory creation and must be treated as revenue expenditure. The decision reinforces accounting standards in tax treatment.

On-Money Payment Addition Quashed as Excel Sheet & Third-Party Statements Found Unreliable

April 27, 2026 5307 Views 0 comment Print

The Tribunal held that additions cannot be sustained without incriminating material directly connecting the assessee to alleged cash payments. Reliance solely on third-party data was found insufficient. The ruling reinforces the need for concrete evidence in tax additions.

Bogus Purchases – Only 0.2% Profit Addition Sustainable, Consistency Prevails: ITAT Mumbai

April 27, 2026 381 Views 0 comment Print

The Tribunal upheld reduced addition as earlier years’ rulings fixed profit element at 0.2%. It stressed that consistent facts require consistent treatment. Key takeaway: uniform approach must be followed across years.

Penalty on Share Premium Valuation Deleted – Bona Fide Claim Not Concealment

April 27, 2026 372 Views 0 comment Print

ITAT Pune deletes ₹4.83 lakh penalty under Section 271(1)(c), holding that a bona fide difference in share valuation methods (NAV vs DCF) does not amount to furnishing inaccurate particulars; mere rejection of a claim cannot trigger penalty.

ITAT Deletes Additions Due to Unreliable Third-Party Evidence in 153C Proceedings

April 27, 2026 501 Views 0 comment Print

The Tribunal held that additions under Section 153C cannot be sustained when based on unverified third-party statements and documents. It found the evidence lacked credibility and was not corroborated. The ruling highlights strict evidentiary standards in search-based assessments.

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