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Section 143(2) Notice by Wrong Officer Makes Assessment Null & Void: ITAT Kolkata

June 27, 2026 576 Views 0 comment Print

The ITAT Kolkata held that the assessment was invalid because the statutory notice under Section 143(2) was issued by a non-jurisdictional Assessing Officer. The Revenue’s appeal on merits became infructuous.

Limited Scrutiny Cannot Be Expanded Without CBDT Approval: ITAT Kolkata

June 27, 2026 471 Views 0 comment Print

Tribunal held that the Assessing Officer exceeded the scope of limited scrutiny by making disallowances beyond the selected issues without following the prescribed CBDT procedure. Such additions were held to be unsustainable.

ITAT Deletes Addition as TDS Deduction Alone Did Not Establish Income Accrual

June 27, 2026 192 Views 0 comment Print

The ITAT Delhi held that deduction of TDS by the payer does not by itself establish that income has accrued to the recipient. It ruled that income must be recognised based on the assessees accounting method and completion of services.

Addition for TDS Receipt Mismatch Rejected as Assessee’s Explanation Was Consistently Accepted

June 27, 2026 123 Views 0 comment Print

The Bombay High Court upheld the Tribunals order, holding that acceptance of the assessees explanation on reconciliation of professional receipts did not raise any substantial question of law.

ITAT Deletes AIR-Based Addition as Professional Receipts Declared Exceeded AIR Figures

June 27, 2026 165 Views 0 comment Print

The ITAT Mumbai held that additions based solely on AIR information were unsustainable when the assessee had disclosed professional receipts higher than those reflected in the AIR and no contrary evidence was produced.

ITAT Deletes Transfer Pricing Adjustment as TPO Used Ad Hoc Method Instead of Section 92C

June 27, 2026 138 Views 0 comment Print

The ITAT Mumbai held that transfer pricing adjustments for intra-group services were unsustainable because the TPO determined the arms length price without applying any prescribed method under Section 92C. It directed deletion of the adjustments on this technical ground.

Section 68 Addition Unsustainable as Documentary Evidence Established Loan Transactions

June 27, 2026 219 Views 0 comment Print

The ITAT Ahmedabad held that the assessee had discharged its burden under Section 68 by producing confirmations, PAN, bank statements and income-tax records. The Revenue’s additions were deleted as no contrary evidence was produced.

ITAT Restores Appeal as CIT(A) Failed to Examine Claim That Bank Account Did Not Belong to Assessee

June 27, 2026 150 Views 0 comment Print

The Tribunal held that the assessee’s contention regarding ownership of the bank account required proper verification before sustaining the addition under Section 69A. The matter was remanded for fresh adjudication.

ITAT Quashes Section 153C Proceedings as Satisfaction Note Missed Mandatory Finding

June 27, 2026 204 Views 0 comment Print

The Tribunal held that proceedings under Section 153C were invalid because the satisfaction note did not record that the seized material had a bearing on the determination of the assessee’s total income. The assessment was quashed.

ITAT Quashes Section 153C Assessment as Satisfaction Note Lacked Mandatory Finding

June 27, 2026 159 Views 0 comment Print

The Tribunal held that proceedings under Section 153C were invalid because the satisfaction note did not record that the seized material had a bearing on the determination of the assessee’s total income. The assessment was consequently quashed.

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