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ITAT Condones 972-Day Delay Citing Bona Fide Belief & Age of 71-Year-Old Assessee

November 9, 2025 756 Views 0 comment Print

 ITAT held that the delay in filing appeal was caused by genuine reasons, including the taxpayer’s age and misunderstanding of online procedures. The case was remanded to CIT(A) for fresh adjudication on merits.

ITAT Quashes 153C Assessments as Time-Barred: Six-Year Limitation Upheld

November 9, 2025 639 Views 0 comment Print

Delhi ITAT held that AYs 2010–11 and 2011–12 fell outside the limitation for Section 153C and found no valid incriminating material for later years, setting aside all related assessments.

Disallowance for Pension Bond Interest Remanded Due to Wrong ITR Reporting

November 9, 2025 558 Views 0 comment Print

ITAT Hyderabad sent back the disallowance of Rs. 25.93 crore on pension bond adjustments and Rs. 21.92 crore on pension trust payments for verification due to contradictory claims and ITR reporting errors.

Section 54 Relief Upheld as Property Reinvestment Delay Beyond Assessee’s Control

November 9, 2025 891 Views 0 comment Print

ITAT upheld reopening of assessment but allowed Section 54 exemption, ruling that construction delay due to YEIDA’s possession issues was beyond assessee’s control and thus eligible for relief.

No Room for Double Assessment: ITAT Deletes ₹45 Crore Bogus-Loss Addition

November 9, 2025 363 Views 0 comment Print

The tribunal upheld deletion of ₹45 crore additions where losses from share transactions were disallowed as bogus. It held that all transactions were recorded, disclosed, and supported by evidence.

ITAT Delhi Rules Entertainment Tax Subsidy as Capital Receipt in PVR Ltd. Case

November 9, 2025 432 Views 0 comment Print

ITAT Delhi upholds capital receipt status of E-tax subsidies and deletes disallowances on leasehold expenses, Section 14A, bank charges, and MAT additions for PVR Ltd.

Updated 26AS Can’t Shift Income — ITAT Deletes Wrong-Year Addition

November 9, 2025 660 Views 0 comment Print

The Tribunal condoned an 86-day delay in filing the appeal, accepting the assessee’s unavoidable family issues as a reasonable cause. This confirms that genuine reasons can justify late appeals under tax law.

Common Area Maintenance Is a Contract — ITAT Again Says 194C, Not 194I, for PVR Inox

November 9, 2025 477 Views 0 comment Print

The Tribunal held that common area maintenance (CAM) charges are separate from rent and constitute contractual payments, making them liable for TDS under Section 194C. The AO is directed to recompute CAM charges accordingly.

No Defect in Books, No Section 68- When Books Are Clean, Additions Can’t Stand

November 9, 2025 900 Views 0 comment Print

Tribunal held that incremental cash deposits in bank accounts cannot be treated as unexplained under Section 68 without concrete evidence. Addition of Rs. 40.32 lakh was deleted.

Incorrect Approval Dooms 148 Notice: ITAT Quashes Reassessment Under New Regime

November 9, 2025 846 Views 0 comment Print

The Tribunal held that the notice u/s 148 issued without prior approval of the specified authority under Section 151(ii) is invalid. The reassessment order for AY 2017-18 was quashed.

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