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Estimated Commission Addition Unsustainable Without Rejecting Books

January 9, 2026 813 Views 0 comment Print

The issue was whether commission income could be estimated without rejecting books of account. The Tribunal ruled that estimation without invoking section 145(3) and section 144 is impermissible.

Section 68 Addition Deleted After Loan Genuineness Proven

January 9, 2026 615 Views 0 comment Print

The Revenue argued that routing through banking channels was insufficient. The Tribunal rejected this contention, holding that complete documentary evidence satisfied all requirements of Section 68.

Accommodation Entry Allegation Rejected for Want of Proof

January 9, 2026 546 Views 0 comment Print

The ruling reiterates that reassessment cannot be sustained where documentary evidence shows no loan transaction. Incorrect third-party information cannot justify reopening.

ITAT Pune Deletes Section 234E Late Fee for Pre-1 June 2015 TDS Return Processing

January 9, 2026 669 Views 0 comment Print

The case dealt with a TDS return processed in March 2015 where late fee was levied. The Tribunal held such levy to be without jurisdiction under the law then in force.

Section 80P Deduction Cannot Be Denied by CPC for AY 2019-20

January 9, 2026 366 Views 0 comment Print

The issue was whether CPC could disallow Section 80P deduction while processing the return under Section 143(1). The Tribunal held that CPC lacked such power for AY 2019-20 as the enabling amendment came later.

No Penalty for Recharacterising Capital Gains as Business Income

January 9, 2026 468 Views 0 comment Print

The Assessing Officer imposed penalty after treating disclosed capital gains as business income. The Tribunal ruled that classification disputes, without suppression of facts, cannot justify penalty.

Section 69 Addition Quashed Because Housing Loan Explained Source

January 9, 2026 498 Views 0 comment Print

The issue was whether cash and cheque payments could be taxed as unexplained investment in AY 2013–14. The Tribunal held that the major payments pertained to FY 2010–11 and could not be assessed in a later year.

Reopening Quashed for Mechanical “Bogus Sub-Contractor” Reasons

January 9, 2026 348 Views 0 comment Print

The issue was whether reassessment based on identical, template reasons was valid. The Tribunal held that reopening without independent application of mind amounts to borrowed satisfaction and is invalid in law.

No Section 68 Addition When Capital Introduction Pertains to Another Year

January 9, 2026 444 Views 0 comment Print

The Tribunal upheld deletion of a ₹2.27 crore addition after finding that the capital deposit did not pertain to the assessment year in question. Without a year-wise nexus, section 68 could not be invoked.

Low-Margin Trading Business Justifies 2% Profit Estimation

January 9, 2026 681 Views 0 comment Print

The issue was determination of income when the assessee failed to maintain books of account. The Tribunal held that an 8% or 4% estimate was excessive and fixed profit at a reasonable 2% of turnover.

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