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Final Assessment Quashed for Missing One-Month DRP Deadline

December 21, 2025 546 Views 0 comment Print

The issue was whether the final order was passed within the statutory timeline after DRP directions. The Tribunal held that delay beyond one month under section 144C(13) renders the order void.

Loss-Making Co-operative Society Not Liable on Bank Deposits

December 21, 2025 309 Views 0 comment Print

The dispute involved taxing deposits despite a declared loss. The Tribunal held that when accounts show a loss, blanket addition of deposits is unsustainable.

Reassessment Quashed for Wrong Sanction Under Section 151

December 21, 2025 609 Views 0 comment Print

The Tribunal held that reassessment issued beyond three years requires approval from the PCCIT and not the PCIT. Since sanction was obtained from an incompetent authority, the entire reassessment was held void ab initio.

Profit Estimated as Safeguard; Bulk Cash Credit Addition Set Aside

December 21, 2025 351 Views 0 comment Print

The Tribunal upheld deletion of additions where receipts were linked to declared sales and no evidence of cash back was shown. Acceptance of sales negates Section 68 in the absence of proof.

ITAT Grants Last Chance in ₹2.28 Cr Unexplained Property Investment Case

December 21, 2025 255 Views 0 comment Print

ITAT Ahmedabad remanded a ₹2.28 crore unexplained property investment case to the AO, allowing the assessee one final opportunity to provide supporting documents, while imposing a ₹5,000 cost for non-compliance.

Interest from Private Banks Eligible for 80P Deduction: ITAT Pune Clarifies

December 21, 2025 558 Views 0 comment Print

ITAT Pune ruled that interest earned by a cooperative society from ICICI and HDFC banks retains its character as business income and qualifies for deduction under section 80P(2)(a).

Illiteracy and Notice Errors Save ₹2.61 Cr in ITAT Delhi Ruling

December 21, 2025 330 Views 0 comment Print

ITAT Delhi overturned a ₹2.61 crore addition under sections 144/147, noting notices were sent to the wrong address and the illiterate assessee was deprived of proper hearing.

Single Section 153D Sanction for Seven Years Deemed Illegal by ITAT

December 21, 2025 657 Views 0 comment Print

The ITAT Delhi ruled that a single approval for seven assessment years under Section 153D, issued without application of mind, is invalid, quashing the related assessment orders. The case underscores the need for careful, year-specific scrutiny.

Section 153C Notice Invalid Due to Missing ₹50 Lakh Asset Satisfaction

December 21, 2025 492 Views 0 comment Print

Upholding the appellate authority, the Tribunal confirmed that jurisdiction cannot be assumed casually against a non-searched person. Statutory satisfaction requirements are mandatory, not procedural.

Section 148 Notice by Local AO Invalid Under 2022 Scheme

December 21, 2025 681 Views 0 comment Print

The Tribunal held that notices issued under Section 148 must follow the faceless mechanism prescribed by the CBDT Scheme, 2022. Issuance by the Jurisdictional Assessing Officer instead of the Faceless Assessing Officer vitiated the proceedings.

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