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Prior-Period Expenses Allowed When Liability Crystallises in Current Year

January 15, 2026 1275 Views 0 comment Print

The ITAT ruled that customer discounts are deductible when quantified and finalised in the year of claim, even if labelled as prior-period items. The decision reinforces that timing of crystallisation outweighs book classification.

Bogus Purchase Addition Deleted for Lack of Independent Enquiry

January 15, 2026 606 Views 0 comment Print

The Tribunal examined whether purchases could be treated as bogus solely on investigation inputs. It held that without independent verification or rebuttal of documentary evidence, the addition could not survive.

Customer Advances Not Cash Credits Under Section 68

January 15, 2026 798 Views 0 comment Print

The tribunal held that advances received from customers for future services cannot be treated as unexplained cash credits. Once the assessee proves identity, nature, and business purpose, Section 68 addition fails.

Mechanical Approval Quashes Search Assessment Under Section 153A

January 15, 2026 417 Views 0 comment Print

The tribunal held that prior approval under Section 153D was granted mechanically without application of mind. Such invalid sanction vitiated the entire search assessment, leading to quashing of the order.

ITAT Delhi Denied Indexation as Factory Building Treated as Depreciable Asset

January 15, 2026 519 Views 0 comment Print

The dispute centered on whether indexation could be claimed on a factory building sold along with land. The tribunal held that once depreciation is claimed, section 50 applies, and indexation is not permissible.

Salary Paid and TDS Deducted, Yet Proof Still Required

January 15, 2026 837 Views 0 comment Print

The tribunal held that salary payments, even with TDS and bank transfers, require proof of genuineness and business nexus. The matter was remanded to the Assessing Officer for fresh verification of employee evidence.

CIT(A) Can’t Dismiss Appeal for Non-Prosecution Without Merits: ITAT Chandigarh Remands Case

January 15, 2026 579 Views 0 comment Print

The Tribunal held that an appeal cannot be dismissed for non-prosecution and must be decided on merits. The matter was remanded for fresh adjudication in compliance with statutory requirements.

No Hearing, No Merits: Income Tax Appellate Orders Quashed and Sent Back

January 15, 2026 1089 Views 0 comment Print

The issue was whether appeals could be decided ex parte without examining merits. The tribunal held that lack of effective hearing violates natural justice, warranting remand for fresh adjudication.

TP Adjustment Set Aside Due to Improper Segment Aggregation; Non-Compete Fee Held Revenue

January 15, 2026 438 Views 0 comment Print

The Tribunal held that AMC services and marketing support services could not be aggregated for transfer pricing purposes. It directed separate segment-wise benchmarking based on functional differences.

Penalty for Underreporting Reopened Due to Unexamined Reasonable Cause

January 15, 2026 1017 Views 0 comment Print

The Tribunal set aside the confirmed penalty where non-filing of return was attributed to medical reasons. The case was remanded for fresh examination of reasonable cause before sustaining penalty under Section 270A.

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