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Section 153A Invalid Where No Incriminating Material Found in Search: ITAT Delhi

January 20, 2026 453 Views 0 comment Print

The Tribunal held that assessments under Section 153A cannot be sustained when no incriminating material is found at the assessees premises. Additions based on third-party material were quashed as being without jurisdiction.

Belated Return Under Section 148 Still Requires 143(2) Notice: ITAT Delhi

January 20, 2026 1182 Views 0 comment Print

The Tribunal ruled that treating a belated return as non est is legally unsustainable. Absence of a Section 143(2) notice invalidates the entire reassessment proceedings.

Contribution to State Nodal Agency Allowed as Application of Income

January 20, 2026 189 Views 0 comment Print

Payments to AwasBandhu were allowed as application of income. The Tribunal held such statutory contributions further public purposes and cannot be treated as non-business or taxable expenses.

Cash Advances Not Taxable Before Project Completion Under PCM

January 20, 2026 306 Views 0 comment Print

The Tribunal held that cash advances/on-money received for an ongoing real estate project cannot be taxed before completion when the Project Completion Method is consistently followed. Income already offered and accepted in the completion year cannot be taxed again earlier.

Addition Deleted for Wrist Watches Due to invocation of Section 69 Instead of 69A

January 20, 2026 303 Views 0 comment Print

The Tribunal held that wrist watches are valuable articles covered under Section 69A, and additions made under Section 69 were unsustainable.

Agreement to Sell Treated as Transfer Date; Section 54 Exemption Allowed: ITAT Mumbai

January 20, 2026 456 Views 0 comment Print

The Tribunal held that an enforceable agreement to sell, supported by advance consideration, constitutes transfer under Section 2(47), entitling the assessee to Section 54 relief.

ITAT Mumbai Upholds Composite Satisfaction u/s 153C; Sustains Partial 69C Addition in Land Deal

January 19, 2026 516 Views 0 comment Print

The Tribunal examined whether a single satisfaction note could sustain reassessment proceedings for multiple years under section 153C. It held that a composite satisfaction is valid when based on common seized material spanning several assessment years.

Technical Mistake in Form 10AB Can’t Block U/s 12A Approval: ITAT Kolkata

January 19, 2026 594 Views 0 comment Print

The Tribunal held that inadvertent mistakes in filing Form 10AB cannot defeat a trust’s right to exemption. Registration was directed where objects and activities were never disputed.

ITAT Ahmedabad Sustains 69C Additions Based on Seized Diaries with Running Ledger

January 19, 2026 525 Views 0 comment Print

The Tribunal held that a continuously maintained ledger found during search constituted reliable evidence. Additions for unexplained expenditure under section 69C were sustained based on corroborated diary entries.

ITAT Delhi Quashed Cash Addition for Invalid WhatsApp Digital Evidence

January 19, 2026 4599 Views 0 comment Print

The issue was whether a WhatsApp image from a third party could justify a cash addition. The Tribunal held the digital evidence inadmissible due to lack of lawful collection and chain of custody, deleting the addition.

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