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Section 147 Proceedings Invalid Due to Limitation, ₹3.34 Cr Addition Dropped

December 13, 2025 399 Views 0 comment Print

The Tribunal admitted an additional legal ground under Rule 11, allowing examination of the Section 148 notice on admitted facts. Since the notice was issued after the limitation period, the reassessment order and ₹3.34 crore additions were set aside.

Human probability matters: ITAT upholds deletion of ₹87.34 lakh cash-deposit addition

December 13, 2025 366 Views 0 comment Print

Tribunal upheld CIT(A)’s deletion of addition under Section 69A for cash deposits from painting sales, ancestral jewellery, and customary gifts. Revenue failed to challenge the well-supported factual findings.

ITAT Confirms Section 68 Additions for Unexplained Cash During Demonetisation

December 13, 2025 495 Views 0 comment Print

ITAT Ahmedabad upheld ₹59.9 lakh addition from demonetisation-period cash deposits and GP estimation, confirming the rejection of unverifiable books due to abnormal sales and fraudulent stock.

Cash receipts belonging to Partnership Firm cannot be taxed in hands of partner

December 13, 2025 903 Views 0 comment Print

ITAT ruled that cash recorded in a partner’s name during survey cannot be taxed in his hands when the amounts relate to the firm’s land sales and are recorded in the firm’s books. The key takeaway: assess income in the correct entity.

No Section 271D Penalty on Cash Payment under Pre-Amendment Property Agreement

December 13, 2025 1020 Views 0 comment Print

ITAT held that the obligation to receive cash was rooted in an agreement executed before the 2015 amendment to Section 269SS. Since reasonable cause existed, penalty under Section 271D was not sustainable.

ITAT Overturns Section 69A and 115BBE Addition on Petrol Pump Deposits

December 13, 2025 600 Views 0 comment Print

ITAT Ahmedabad ruled that detailed stock, sales, VAT, and bank records satisfactorily explained cash deposits of ₹2.07 crore, overturning additions made by AO and CIT(A).

Belated Form 10B Doesn’t Warrant Taxing Entire Receipts

December 13, 2025 414 Views 0 comment Print

ITAT Pune held that late filing of Form 10B cannot result in taxing the entire gross receipts; assessment must be made on net surplus after allowing expenses.

Rs. 87.65-Crore ‘Bogus Purchase’ Disallowance Remanded for Fresh Verification

December 13, 2025 681 Views 0 comment Print

ITAT Pune sent back the issue of alleged bogus purchases for A.Y. 2017-18, directing AO to examine GST closure letters, transportation evidence, and other supporting documents to determine genuineness.

Registration Under Section 12AB Restored Due to Reasonable Cause for Non-Response

December 13, 2025 378 Views 0 comment Print

The tribunal held that absence of internet connectivity in a remote area was a valid reason for non-compliance and restored the registration application.

Mixed-Funds Interest Disallowance Needs AO Review

December 13, 2025 216 Views 0 comment Print

The Tribunal ruled that the disallowance of interest on the ground of mixed-funds usage could not be sustained without allowing the AO to verify supporting documents. The matter was remitted to ensure a fresh and fair assessment in accordance with law.

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