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Unexplained Income Reduced from ₹10 Cr to ₹2.22 Cr, Commission to 1% in entry transaction case

October 25, 2025 432 Views 0 comment Print

ITAT Delhi partly allowed assessee’s appeal, reducing unexplained income from ₹10.08 crore to ₹2.22 crore and lowering commission on inter-mediated transactions from 3% to a fair 1%, emphasizing verification of cash and cheque entries under same code.

ITAT Condones 146-Day Appeal Delay Due to Assessee’s Absence from India

October 25, 2025 432 Views 0 comment Print

ITAT Amritsar condoned the 146-day delay in a senior citizen’s appeal, accepting passport evidence of her absence from India as sufficient cause, and remanded the case for fresh assessment.

Assessment Order in Deceased Assessee’s Name Not Sufficient to Quash Proceedings

October 25, 2025 582 Views 0 comment Print

ITAT Chandigarh ruled that a CIT(A) order is not void simply because it names the deceased assessee. The Tribunal restored the case, directing the CIT(A) to admit evidence due to the assessee’s prior illness.

Hawala Purchase Additions restricted to 15%, Typo Not Justify Full disallowance

October 25, 2025 600 Views 0 comment Print

ITAT Pune upheld CIT(A)’s order restricting Hawala purchase additions to 15%, ruling that a typographical error does not warrant full disallowance.

ITAT Delhi Deletes 25% “Bogus Sales” Disallowance; Section 37 Not Applicable to Sales

October 24, 2025 990 Views 0 comment Print

ITAT Delhi held that sales made to Jyoti Products were genuine, supported by ledgers and invoices. The 25% disallowance by the AO under Section 37 was deleted, as Section 37 applies only to business expenditure, not sales transactions.

Transfer Pricing adjustment of advertisement, marketing and promotion deleted as not an international transaction

October 24, 2025 444 Views 0 comment Print

ITAT Kolkata held that the advertisement, marketing and promotion expenses [AMP Expense] not an international transaction and accordingly, the TP adjustment made by Transfer Pricing Officer/ AO is to be deleted. Accordingly, appeal allowed to that extent.

No Office, No Expatriates, No PE: ITAT Delhi Rejects Revenue’s Repeated PE Allegation

October 24, 2025 627 Views 0 comment Print

ITAT Delhi held that the absence of office premises and expatriate activity meant the assessee had no Permanent Establishment (PE) in India. The Tribunal ruled that Revenue cannot rely solely on past orders without verifying current-year facts.

Unexplained money u/s. 68 restored back as basic ingredients satisfactorily not explained

October 24, 2025 528 Views 0 comment Print

ITAT Raipur held that matter regarding unexplained money addition under section 68 of the Income Tax Act restored back as basic ingredients required u/s 68, i.e., identity / creditworthiness of the investors and genuineness of transactions not satisfactorily explained.

Transfer of undertaking under court approved scheme doesn’t attract 50B

October 24, 2025 399 Views 0 comment Print

ITAT Mumbai held that transfer of an undertaking under a court-approved scheme cannot be characterised as a slum sale within the meaning of section 2(42C) hence provisions of section 50B not attracted.

Section 80IA(4) deduction allowed based on principle of consistency

October 24, 2025 291 Views 0 comment Print

ITAT Mumbai held that assessee is entitled for deduction under section 80IA(4) of the Income Tax Act on the basis of principle of consistency. Accordingly, appeal of revenue dismissed and order of CIT(A) upheld.

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