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

December 19, 2025 447 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 495 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 231 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 363 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.

Reopening not justified as reasons recorded remained speculative

December 19, 2025 468 Views 0 comment Print

ITAT Delhi held that without a clear and direct connection between the facts and the alleged escapement of income, the reasons recorded remains speculative, therefore, the reopening cannot be justified. Accordingly, appeal allowed to that extent.

Section 44AD Case Can’t Become Blanket Cash Addition; ITAT Surat Sets Aside ₹5.09 Cr Assessment

December 19, 2025 852 Views 0 comment Print

The ITAT held that additions based on incorrect and unreconciled bank data cannot be sustained. The assessment was remanded for fresh verification of actual cash deposits and credits.

Technical Rejection of U/s 12AB Application Set Aside for Fresh Examination

December 19, 2025 366 Views 0 comment Print

The ITAT held that registration cannot be denied based on an incorrect interpretation of trust objects. Where amended deeds and clarifications exist, authorities must examine them before rejecting 12AB registration.

Duplicate PAN & No Hearing: ITAT Sets Aside Reassessments for 5 Years

December 19, 2025 396 Views 0 comment Print

The ITAT held that reassessment based on a duplicate PAN, despite disclosure under a valid PAN, suffers from jurisdictional infirmity. Ex parte orders passed without addressing such objections violate principles of natural justice.

Wrong Sanction Under Section 151 Makes Reassessment Void Ab Initio

December 19, 2025 627 Views 1 comment Print

The ITAT held that reassessment issued after three years is void if approval is taken from an incompetent authority. Wrong sanction under section 151 renders the entire reopening unsustainable in law.

Pure Legal Grounds Allowed to Quash Time-Barred U/s 153C Assessments

December 19, 2025 402 Views 0 comment Print

The ITAT held that undated satisfaction notes defeat jurisdiction under section 153C. In such cases, limitation must be computed from the notice date, making assessments beyond the block period void.

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