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Reassessment Quashed for Escaped Income Below ₹50 Lakh Threshold

December 19, 2025 1206 Views 0 comment Print

The Tribunal examined whether reassessment beyond three years was valid when the assessed escaped income was only ₹13.98 lakh. It held that failure to meet the ₹50 lakh threshold under section 149(1)(b) rendered the reassessment without jurisdiction.

1918-Day Delay Condoned; No Penalty on Excess Section 54F/54B Claim

December 19, 2025 486 Views 0 comment Print

The Tribunal examined whether penalty could be levied for claiming excess deduction under sections 54F and 54B. It held that an inadvertent and promptly corrected mistake does not amount to concealment or furnishing inaccurate particulars.

Technical Delay Can’t Defeat Substantive Justice: ITAT Pune

December 19, 2025 573 Views 0 comment Print

ITAT observed that non-deliberate delay caused by administrative difficulties should not bar access to justice. Relying on Supreme Court precedents, the appeal was revived for merit-based adjudication.

Seller’s Settlement Admission Can’t Implicate Buyer: On-Money Addition Deleted

December 19, 2025 600 Views 0 comment Print

ITAT held that on-money admitted by a seller before the Settlement Commission cannot be presumed against the purchaser without independent evidence. In absence of any seized material or proof of cash payment, the addition u/s 69 was deleted.

Bona Fide Mutuality Claim Bars U/s 271(1)(c) Penalty on Bank Interest

December 19, 2025 480 Views 0 comment Print

The dispute involved penalties on bank interest earned by a mutual entity prior to a change in law. The Tribunal held that a bona fide claim based on settled law cannot be treated as concealment, warranting deletion of penalties.

Section 12AB Registration Can’t Be Cancelled for Procedural Lapses Alone

December 19, 2025 744 Views 0 comment Print

The ITAT held that cancellation of provisional registration merely for non-compliance with notices is unsustainable when lapses are not deliberate. The case was remanded to allow the applicant a fair opportunity to establish genuineness of activities.

NFAC Can’t Dismiss Appeal for Non-Appearance Without Merits Adjudication: ITAT Pune

December 19, 2025 420 Views 0 comment Print

The ITAT held that the appellate authority mechanically affirmed reassessment additions without independent examination of merits. The matter was remanded to grant the assessee a fair and effective opportunity to explain cash deposits and other additions.

Interest on delayed remittance of TDS not deductible as business expense u/s. 37(1)

December 19, 2025 474 Views 0 comment Print

ITAT Hyderabad held that interest paid on account of delayed remittance of TDS cannot be treated as business expenditure under section 37(1) of the Income Tax Act. Accordingly, order disallowing the same is upheld.

Ex-Parte Assessment Appeal Can’t Stand: Matter Sent Back for De Novo Adjudication

December 19, 2025 216 Views 0 comment Print

The case examined whether ex-parte assessment and appellate orders could stand without merit-based adjudication. The Tribunal held that failure to decide all grounds violates natural justice and ordered a fresh assessment.

Section 80JJAA Deduction Remanded Due to Portal Glitch in Form 10DA

December 19, 2025 348 Views 0 comment Print

The ITAT held that a deduction under section 80JJAA cannot be denied merely because Form 10DA was partially invisible on the tax portal. The issue was remanded for limited verification now that the complete form is available.

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