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No Liability Cessation Without Remission: ITAT Deletes Section 41(1) Addition  

April 10, 2026 630 Views 0 comment Print

The Tribunal held that mere non-payment or expiry of limitation does not amount to cessation of liability. In absence of actual benefit or remission, addition under Section 41(1) was deleted.

Late Form 10B Filing Not Fatal—ITAT Allows Exemption if Audit Report Filed Before Processing

April 10, 2026 624 Views 0 comment Print

The issue involved wrong filing of Form 10BB instead of 10B. The tribunal held that correction before processing cures the defect. This ensures that genuine claims are not denied on technical grounds.

Wrong Invocation of Section 153C- ITAT Quashes Assessments Where Assessee Was Himself Searched

April 10, 2026 522 Views 0 comment Print

The issue was whether Section 153C could apply when the assessees own premises were searched. The tribunal held that such a person is a searched person, making Section 153A applicable instead. Consequently, assessments under Section 153C were quashed for multiple years.

ITAT Limits Its Directions – Excludes Comparables Due to Improper Remand to DRP

April 10, 2026 531 Views 0 comment Print

The issue concerned failure to follow tribunal remand directions on comparables. The ruling held that such non-compliance caused procedural irregularity, leading to exclusion of certain comparables and recomputation of ALP.

Partial Disallowance Upheld as Assessee Failed to Prove Full Business Nexus of Expenses

April 10, 2026 321 Views 0 comment Print

The case involved disallowance of business expenses where activity was minimal. ITAT held that existence of even limited business justified partial allowance and restricted disallowance to ₹1 lakh.

ITAT Mumbai Deletes TDS delay Interest as Cheque Tender Date Considered Payment Date

April 10, 2026 339 Views 0 comment Print

The issue was whether delay in cheque clearance attracts TDS interest. ITAT held that payment date is the cheque tender date, and no interest is leviable if submitted within due date.

ITAT Mumbai Restores ₹32.67 Cr Loan Addition Due to Incomplete Verification of Creditors

April 10, 2026 642 Views 0 comment Print

The issue involved large unsecured loans without full supporting evidence. ITAT held that identity and creditworthiness were not properly established and sent the matter back for fresh verification.

CPC Cannot Reduce TDS Credit Based on Turnover Differences in 26AS: ITAT Delhi

April 10, 2026 3627 Views 0 comment Print

The issue involved restriction of TDS credit due to mismatch between Form 26AS and return. ITAT held that such adjustments require verification and cannot be made under Section 143(1).

Fresh U/s 12AB Application Cannot Be Rejected Due to Earlier Denial – ITAT Restores Matter for Reconsideration

April 9, 2026 483 Views 0 comment Print

The issue was whether a fresh registration application can be rejected due to prior denial. ITAT held that earlier rejection does not bar reconsideration if conditions are fulfilled.

APMC Gets Full Exemption – ITAT Condones Delay & Quashes Assessments Despite PAN Error

April 9, 2026 441 Views 0 comment Print

The tribunal addressed whether delay in filing appeals due to procedural difficulties justified condonation. It held that genuine hardship caused by PAN mismatch and filing issues constituted sufficient cause, allowing the appeal.

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