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All ITAT

Same-Day Cash Withdrawal and Deposit Not Unexplained Income

December 22, 2025 711 Views 0 comment Print

The ITAT held that cash redeposited after a clearly documented bank withdrawal cannot be treated as unexplained. The ruling emphasizes that verifiable fund movement defeats section 69A additions.

ITAT Mumbai Quashed Reassessment Notice for Being Issued Beyond Limitation Period

December 22, 2025 960 Views 0 comment Print

The issue was whether a reassessment notice issued after the prescribed time limit was valid. The Tribunal held that notices for the relevant year issued after the cut-off date were barred by limitation, rendering the reassessment void.

FMV Claim Rejected Because No Error Shown in Valuation Methodology

December 22, 2025 270 Views 0 comment Print

The ITAT held that land-levelling and fencing expenses are integral to acquiring agricultural land and qualify for section 54B deduction. The ruling clarifies what constitutes eligible investment despite restricting unregistered costs.

Section 270A Penalty Quashed as Income Was Fully Disclosed but Taxed Under Wrong Head

December 22, 2025 8082 Views 0 comment Print

The issue was whether penalty for misreporting could be levied when income was disclosed but offered under an incorrect head. The Tribunal held that such a classification dispute does not amount to misreporting and deleted the penalty.

Proviso to Section 2(15) Inapplicable to Solar Energy Promotion Activities: ITAT Delhi

December 22, 2025 375 Views 0 comment Print

Noting that exemption was allowed in multiple subsequent years on identical facts, the Tribunal rejected the Revenue’s stand. The addition and denial of exemption were accordingly set aside.

Section 263 Revision Upheld as AO Taxed Only TDS Credit Instead of Undisclosed Commission

December 22, 2025 240 Views 0 comment Print

The ITAT held that taxing only TDS credit, while leaving the underlying undisclosed commission untaxed, is a patent error. Section 263 revision was rightly invoked to protect revenue.

PCIT Cannot Invoke Section 263 When AO Took a Plausible View After Verification of Goodwill Claim

December 22, 2025 246 Views 0 comment Print

The ITAT held that revision under Section 263 was invalid because the Assessing Officer had conducted detailed enquiries into goodwill depreciation. A plausible view taken after scrutiny cannot be branded as erroneous.

Transfer Pricing on Power Supply Must Use Gross Electricity Tariff, Not Base Rate: ITAT Hyderabad

December 22, 2025 333 Views 0 comment Print

ITAT held that arm’s length price for electricity supplied to related entities must be benchmarked against the gross tariff charged by the State Electricity Authority. Excluding mandatory charges distorts comparability and is impermissible.

Section 263 Revision Quashed for Substituting PCIT’s Opinion Over AO’s Due Inquiry

December 22, 2025 234 Views 0 comment Print

The issue was whether revision under section 263 could be invoked to deny 80P deduction on interest from co-operative bank deposits. The ITAT held that such revision is invalid when the AO has taken a legally settled and permissible view.

Bogus Purchase Disallowance Deleted Due to Valid GST and Supporting Evidence

December 22, 2025 1359 Views 0 comment Print

The Tribunal held that purchases supported by invoices, e-way bills, banking payments, and valid GST registration at the time of supply cannot be treated as bogus. Subsequent GST cancellation and non-response by suppliers were held insufficient to justify disallowance.

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