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Difference of Opinion Not Enough to Invoke Revisionary Jurisdiction: ITAT Mumbai

December 18, 2025 573 Views 0 comment Print

The issue was whether a completed assessment could be revised without identifying concrete errors. The Tribunal held that vague observations and absence of specific defects do not justify invoking section 263.

Section 80P Deduction Allowed as Co-operative Bank Treated as Co-operative Society

December 18, 2025 879 Views 0 comment Print

The Tribunal held that interest earned from investments with a co-operative bank registered as a co-operative society qualifies for deduction under Section 80P(2)(d), following jurisdictional High Court rulings.

Income Tax Assessment Quashed Due to Manual Signature in E-Proceedings: ITAT Delhi

December 18, 2025 11649 Views 0 comment Print

The tribunal ruled that an assessment order signed manually instead of digitally in e-proceedings violates binding CBDT instructions and is legally void.

Section 144 Assessment Quashed for Failure to Issue Mandatory Section 143(2) Notice

December 18, 2025 1452 Views 0 comment Print

The tribunal examined whether an assessment under section 144 could survive without issuance of a notice under section 143(2). It held that non-issuance of the mandatory notice rendered the assessment void ab initio.

CSR Donations Eligible for Section 80G Deduction Despite Section 37 Disallowance: ITAT Pune

December 18, 2025 1560 Views 0 comment Print

The Tribunal held that denial of CSR expenditure under Section 37 does not bar deduction under Section 80G. It ruled that eligible donations forming part of CSR must be examined under Chapter VI-A independently. The key takeaway is that CSR-linked donations can still qualify for tax relief if statutory conditions are met.

Reassessment Quashed As AO issuing notice lacked Jurisdiction Over Non-Resident

December 18, 2025 1017 Views 0 comment Print

The tribunal examined whether reassessment could be initiated by an officer lacking jurisdiction over a non-resident assessee. It held that notices issued by an incorrect authority render the entire reassessment void.

Foreign Exchange Loss Allowable as Liability Recognised Under Mercantile Accounting: ITAT Delhi

December 18, 2025 507 Views 0 comment Print

The tribunal held that foreign exchange fluctuation loss was deductible as it was recorded under a consistent mercantile accounting system and in line with applicable accounting standards. The ruling reiterates that such losses are allowable when gains are similarly taxed.

Multiple Opportunities Ignored, Yet ITAT Surat Grants Final Hearing Chance

December 18, 2025 348 Views 0 comment Print

The Tribunal held that dismissal of an appeal without effective hearing violated principles of natural justice. The matter was remanded for fresh adjudication with directions to grant adequate opportunity.

ITAT Mumbai Quashes Reopening Beyond 3 Years for Sanction by Wrong Authority

December 18, 2025 717 Views 0 comment Print

The tribunal held that a reassessment notice issued after three years was invalid as sanction was taken from an incompetent authority. The assessment was quashed for non-compliance with section 151(ii) of the Income Tax Act.

Failure to Scrutinise Exempt LTCG from Penny Stock Justifies Section 263 Action: ITAT Surat

December 18, 2025 393 Views 0 comment Print

The Tribunal upheld revision where the Assessing Officer failed to examine an exempt LTCG claim linked to penny stock manipulation. The ruling affirms that lack of inquiry makes an order erroneous and prejudicial.

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