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Repayment of Friendly Loan Explained: ITAT Deletes ₹12.50 Lakh Addition u/s 69A

December 12, 2025 435 Views 0 comment Print

ITAT held that the assessee had proved identity, creditworthiness, and genuineness of the lender through affidavits, ITR and audited accounts. Since the AO brought no contrary evidence, the Section 69A addition was deleted.

Section 68 Share Premium Addition Remitted as Evidence Was Not Examined

December 12, 2025 267 Views 0 comment Print

Tribunal remanded the case after finding that documentary evidence submitted during assessment was not examined. The matter is sent back for fresh evaluation with an opportunity of hearing.

Disallowance Cut to 5% Since AO Failed to Prove Entire Sales Were Unexplained

December 12, 2025 252 Views 0 comment Print

ITAT held that the entire disputed turnover cannot be added when purchases are accepted and books are not rejected. Only the embedded profit is taxable, leading to restriction of addition to 5% of turnover.

Remand Ordered Since AO Adopted U/s 143(1) Figures Without Addressing Disallowances

December 12, 2025 378 Views 0 comment Print

ITAT ruled that a scrutiny order cannot override a 143(1) intimation if the AO fails to examine pending 154 grievances. The case was remanded because the core adjustments were never adjudicated.

ITAT Again Follows Its Own Precedents: Qualcomm Royalty from Foreign OEMs Not Taxable in India

December 12, 2025 333 Views 0 comment Print

RBI introduces a uniform framework governing interest rates, premature withdrawal penalties, and deposit treatment to ensure fairness and transparency across Local Area Banks.

Section 10(23C)(iiiab) Rejected for Lack of Educational Activity and Government Funding

December 12, 2025 318 Views 0 comment Print

The Tribunal ruled that the entity did not qualify as an educational institution or as substantially government-financed, leading to denial of Section 10(23C)(iiiab) exemption. The dispute over taxing gross receipts was remanded for a fresh decision. Key takeaway: fund management alone cannot justify exemption.

ITAT Rejects Bogus Debtors Theory: Rs. 65.19 Lakh Addition Deleted for Lack of Evidence

December 12, 2025 285 Views 0 comment Print

The Tribunal held that additions based solely on earlier-year assumptions cannot sustain without year-specific evidence. It found no material to show that current-year sales or debtors were bogus. The takeaway is that assessments must be supported by concrete evidence, not presumptions.

ITAT Deletes Section 69 Additions Over Unsupported On-Money Claims

December 12, 2025 591 Views 0 comment Print

ITAT Mumbai deleted Section 69 additions as the Revenue relied only on uncorroborated statements and pen-drive data from third parties, violating natural justice. Suspicion alone cannot justify tax additions.

Section 54 Deduction Upheld for Pre-Amendment Foreign Property Purchase

December 12, 2025 426 Views 0 comment Print

Tribunal rules that Section 54 deduction applies to property purchased outside India before the 2015 amendment, overturning CIT(A) decision.

Charitable Trust Registration Remanded After ITAT Finds Evidence Ignored

December 12, 2025 261 Views 0 comment Print

The ITAT Amritsar remanded the 12A registration application after the CIT(E) ignored documentary proof of charitable activities. The trust must now be reconsidered with full verification of invoices, bank statements, and photographs.

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