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Appeal Rejected as Not Maintainable Because Filed Before Incorrect ITAT Bench

March 2, 2026 2370 Views 0 comment Print

The Tribunal held that an appeal filed before a Bench lacking territorial jurisdiction is not maintainable and cannot be transferred. Liberty was granted to approach the correct Bench with a delay condonation petition.

No TDS on Excess Interest Spread as Originator Not an Investor Under Section 194LBC

March 2, 2026 633 Views 0 comment Print

The Tribunal held that EIS paid to originators is not subject to TDS because the originator had not subscribed to PTCs and was not an investor. Since statutory conditions under Section 194LBC were not met, demand under Sections 201 and 201(1A) was deleted.

ITAT Mumbai Denied Section 80JJAA Deduction as Claim Not Made in Original Return

March 2, 2026 2361 Views 0 comment Print

ITAT Mumbai held that deduction under Section 80JJAA cannot be allowed when not claimed in the original return of income. Section 80A(5) bars such belated claims raised for the first time before appellate authorities.

Rs. 50 Lakh LIC Investment Treated as Unexplained Due to Failure to Prove HUF Source

March 2, 2026 873 Views 0 comment Print

The Tribunal upheld addition under Section 69 as the assessee failed to establish that the LIC investment belonged to the HUF. Mere assertion of agricultural income without documentary evidence was held insufficient.

153A Assessment Quashed Because No Incriminating Material Found in Assessee’s Search

March 2, 2026 486 Views 0 comment Print

ITAT Delhi upheld CIT(A) s order holding that reassessment under Section 153A cannot stand without incriminating material seized from the assessee. The Revenue’s appeal was dismissed.

Interest Under Section 28 of Land Acquisition Act Not Taxable as ‘Other Sources’: ITAT Delhi

March 2, 2026 1401 Views 0 comment Print

ITAT Delhi held that interest awarded under Section 28 is an accretion to compensation and cannot be taxed as income from other sources. The appeal was allowed following Supreme Court precedent.

Section 153C Assessment Quashed Because Consolidated Satisfaction Note Lacked Year-Wise Incriminating Material

March 2, 2026 1455 Views 0 comment Print

ITAT Delhi held that recording a single satisfaction note for multiple assessment years violates Section 153C requirements. As no year-specific incriminating material was identified, the assessments were quashed along with the related penalty.

ITAT Allows Project Completion Method Because AO Failed to Invoke Section 145(3)

March 1, 2026 921 Views 0 comment Print

Tribunal held that rejection of the Project Completion Method was invalid as the Assessing Officer did not record satisfaction under section 145(3). Income was directed to be recomputed under the method consistently followed by the assessee.

ITAT Allows Software Expenses as Revenue Because Licences Were Short-Term and Non-Exclusive

March 1, 2026 1155 Views 0 comment Print

Tribunal held that application software licences with limited duration and no ownership rights are revenue expenditure. It deleted the disallowance and ruled that remand by the Commissioner (Appeals) was unjustified.

Excel Sheet Alone Not Sufficient Proof: ITAT Ahmedabad Deletes Cash Payment Addition

March 1, 2026 3492 Views 0 comment Print

ITAT Ahmedabad held that an unsigned Excel sheet found during survey, without corroborative evidence, cannot justify addition for alleged cash payments.

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