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ITAT Deletes ₹18.24 Crore Addition as Corrupted Computer Records cannot Override Audited Books

June 20, 2026 315 Views 0 comment Print

The Hyderabad ITAT held that incomplete data retrieved from an inoperative computer could not prevail over audited books of account. It deleted the addition after finding no evidence of suppressed receipts or unexplained expenditure.

ITAT Quashes Section 153C Assessment as Satisfaction Note Was Common for Multiple Years

June 20, 2026 267 Views 0 comment Print

The ITAT Delhi held that a consolidated satisfaction note covering several assessment years without year-specific analysis failed to satisfy the mandatory requirements of Section 153C. It quashed the assessment and dismissed the Revenue’s appeal.

Section 263 Revision Invalid as Mandatory Section 143(2) Notice Was Never Issued

June 20, 2026 189 Views 0 comment Print

The ITAT Kolkata held that reassessment completed without issuing the mandatory notice under Section 143(2) was a nullity in law. Since the original assessment was invalid, the revisionary proceedings under Section 263 could not be sustained. The appeal of the assessee was allowed.

Interest from Overseas Head Office & Branches Not Taxable as It Constitutes Transactions with Self

June 20, 2026 120 Views 0 comment Print

The Mumbai ITAT held that interest received by an Indian branch from its overseas head office and branches is not taxable under the domestic law as it represents transactions with self. The Tribunal applied the principle of mutuality and dismissed the Revenue’s challenge.

Trust’s Conference Hall Rental Income Taxable as Business Income: ITAT Delhi

June 20, 2026 150 Views 0 comment Print

ITAT Delhi held that receipts from hiring conference and auditorium facilities constituted business income under Section 11(4A) as the charitable society actively provided commercial facilities beyond passive letting. The assessee’s appeals were dismissed.

ITAT Deletes Section 271D Penalty as AO Failed to Record Satisfaction in Assessment Order

June 20, 2026 222 Views 0 comment Print

The ITAT observed that recording satisfaction for one penalty provision cannot substitute the statutory requirement for initiating proceedings under Section 271D. The penalties were therefore set aside following the Supreme Court’s decision in Jai Laxmi Rice Mills.

ITAT Deletes 200% Penalty as Consultant’s Error Was a Bona Fide Arithmetical Mistake

June 20, 2026 2625 Views 0 comment Print

ITAT Ahmedabad held that an arithmetical mistake committed by the assessee’s consultant did not amount to misreporting of income under Section 270A(9). The penalty was cancelled as there was no misrepresentation or suppression of facts.

ITAT Annuls Section 153A Assessment as Search Warrant Was Not in Assessee’s Name

June 20, 2026 153 Views 0 comment Print

The Tribunal affirmed the CIT(A)’s order annulling assessments because the search was not conducted in the assessee’s name. It also noted that the Revenue’s appeals were not maintainable due to the low tax effect.

ITAT Rejects Recall Plea as COVID Limitation Extension Not Apply to Assessment Proceedings

June 20, 2026 168 Views 0 comment Print

The ITAT held that the Supreme Court’s COVID-19 limitation extension did not apply to statutory timelines for completing income-tax assessments. It dismissed the Revenue’s recall application and upheld the earlier order quashing the assessment as time-barred.

ITAT Deletes GP Addition as AO Failed to Reject Books Under Section 145(3)

June 20, 2026 243 Views 0 comment Print

The ITAT Raipur held that estimated gross profit addition on unrecorded sales cannot be sustained when the Assessing Officer has not rejected the books of account under Section 145(3). The Tribunal deleted the addition after finding the assessment contrary to settled legal principles.

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