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Assessment u/s. 153C quashed due to lack of jurisdiction

December 23, 2025 630 Views 0 comment Print

ITAT Jaipur held that assessment under section 153C of the Income Tax Act stands quashed due to lack of jurisdiction since there was no transfer of the case of the assessee from Delhi to Jaipur.

Reassessment Fails When Jurisdictional Officer Issues Section 148 Notice

December 23, 2025 2493 Views 0 comment Print

The Tribunal held that after 29-03-2022, only a Faceless Assessing Officer is empowered to issue notices under Section 148. Notices issued by a jurisdictional officer were declared void, vitiating the entire reassessment.

Zero Revenue Alone Not a Ground to Disallow Business Expenses: ITAT Delhi

December 23, 2025 471 Views 0 comment Print

The Tribunal partly allowed the Revenue’s appeal by holding that interest incurred on borrowings used for project development must be capitalised. Absence of evidence showing alternative use of funds justified capitalization.

Delayed Filing Blocks 80P Deduction: ITAT Upholds CPC Adjustment

December 23, 2025 717 Views 0 comment Print

ITAT Bangalore rules that Section 80P deductions cannot be claimed if the return is filed after the due date. The decision reinforces compliance with Section 80AC(ii) and aligns with Madras HC precedent.

No Hearing, No Finality: ITAT Restores 69 Addition in Reassessment to AO

December 23, 2025 426 Views 0 comment Print

ITAT Bangalore directs reassessment with full hearing for an agriculturist after procedural lapses in notices and missed hearings. The ruling emphasizes the importance of fair opportunity under Sections 148 and 144B.

Section 68 Addition Cannot Be Taxed Twice, ITAT Directs Netting Off from Business Receipts

December 23, 2025 606 Views 0 comment Print

ITAT Visakhapatnam held that unexplained cash credit under Section 68 must be netted off against business income to prevent double addition. The ruling ensures accurate assessment and fair taxation.

Failure to Prove Cash Source Justifies Addition Under Section 69A: ITAT Hyderabad

December 23, 2025 669 Views 0 comment Print

Cash deposits were rightly taxed as unexplained money when the assessee failed to discharge the primary burden of proof. Absence of contemporaneous evidence defeats claims of redeposit of cash.

Buyback through High Court approved scheme needs verification of NAV valuation u/r 11UA: Matter remitted

December 23, 2025 492 Views 0 comment Print

ITAT Chennai held that the matter of buyback through High Court approved scheme of arrangment remitted back for verification of NAV valuation under rule 11UA and also to analyize applicability of section 115QA. Accordingly, appeal restored back.

Section 153(3)(ii) Prevails Over Section 153(2A) in Special Audit Cases: ITAT Lucknow

December 23, 2025 342 Views 0 comment Print

The ruling clarifies that Section 153(3)(ii) operates as an exception to the normal limitation framework. When assessments are made to give effect to appellate directions involving special audits, no fixed time limit applies.

Provision of future expense allowed as deduction u/s. 37(1) based on matching principle of accountancy

December 23, 2025 906 Views 0 comment Print

ITAT Jaipur held that claim on account of provision of future expense is allowable under section 37(1) of the Income Tax Act as per matching principle of accountancy. Accordingly, appeal is allowed.

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