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Reassessment Quashed as Time-Barred Due to Post-2021 Notice for AY 2015–16

April 11, 2026 930 Views 0 comment Print

The Tribunal invalidated reassessment proceedings since the Section 148 notice was issued after 01.04.2021, making it time-barred. The ruling reinforces strict limitation compliance for reopening cases.

Deduction u/s. 10A entitled before setting off carry forward losses and unabsorbed depreciation

April 10, 2026 474 Views 0 comment Print

ITAT Agra held that the assessee is entitled to claim deduction u/s. 10A of the Income Tax Act before setting off carry forward losses and unabsorbed depreciation. Accordingly, appeal of the assessee succeeds on this ground.

No Sections 12AB and 80G denial if No Evidence of Community Bias or Non-Genuine Activities

April 10, 2026 531 Views 0 comment Print

The ruling held that incomplete documentation or minor deficiencies cannot be sole grounds for denial of registration. It emphasized that such issues may be examined during assessment proceedings.

₹903 Crore ESOP Expenditure Allowed as Business Expense Due to Binding HC Ruling

April 10, 2026 567 Views 0 comment Print

The Tribunal upheld deduction of ESOP expenses under Section 37(1) by relying on binding jurisdictional High Court precedent. It ruled that prior judicial decisions in the assessee’s own case justified deletion of disallowance.

No Section 68 Addition on Sales Already Offered to Tax: ITAT Mumbai

April 10, 2026 666 Views 0 comment Print

The Tribunal held that recorded sales forming part of turnover cannot be treated as unexplained cash credits. The key takeaway is that taxing gross sales again is impermissible in law.

Registration u/s. 12AB cannot be rejected without examining incidental nature of receipts: Matter restored

April 10, 2026 417 Views 0 comment Print

ITAT Mumbai held that rejection of registration under section 12AB of the Income Tax Act treating receipts and income from sale of agro and Gaushala products as commercial without examining the receipts being incidental and ancillary is not justifiable. Accordingly, matter restored to file of CIT(E).

Unexplained Cash Deposits Addition Reduced Because Only Peak Balance Taxable: ITAT Ahmedabad

April 10, 2026 627 Views 0 comment Print

ITAT confirmed validity of reassessment based on cash deposit information. However, it reduced addition by applying peak credit theory due to withdrawal patterns

ITAT Delhi Invalidates 153C Proceedings Because Satisfaction Note Lacked Income Link

April 10, 2026 465 Views 0 comment Print

ITAT held that failure to record how seized material impacts taxable income invalidates proceedings. All assessments were quashed due to defective satisfaction note.

Section 271(1)(c) Penalty Upheld Due to Non-Bona Fide Claims & Failure to Disclose Income

April 10, 2026 333 Views 0 comment Print

The Tribunal held that omission of taxable foreign exchange gain in the return attracts penalty. It noted that disclosure during assessment does not absolve liability. The ruling highlights importance of correct income reporting.

Delay in Appeal Condoned Due to Genuine Lack of Awareness by Senior Citizen Assessee

April 10, 2026 525 Views 0 comment Print

The Tribunal observed that the assessee could not participate in proceedings due to lack of knowledge. It remanded the matter to ensure proper hearing and adjudication on merits.

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