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Levy of 234E Fee Through Section 200A Intimation Before 01.06.2015 Not Sustainable

November 4, 2025 408 Views 0 comment Print

ITAT Chennai allowed the appeal of MLS Enterprises for statistical purposes, subject to a ₹10,000 cost, restoring the matter to the CIT(A). The central issue is the prospective nature of the Section 234E penalty levied under Section 200A.

ITAT Remands Assessment Due to Missing DIN in Order Body

November 4, 2025 609 Views 0 comment Print

The ITAT sent a tax assessment case back to the CIT(A) for reconsideration, citing the assessee’s claim of DIN absence in the assessment order. The appellate authority must now adjudicate on both the merits and the CBDT Circular No. 19/2019 compliance.

ITAT Dehradun Deletes Penalty for Lack of Specificity under Section 270A

November 4, 2025 1050 Views 0 comment Print

The ITAT Dehradun set aside a penalty under Section 270A, holding that the Assessing Officer failed to specify the exact clause of misreporting invoked. The penalty was declared invalid and deleted.

Ad-hoc Expense Disallowance Set Aside by ITAT Jodhpur for Non-Rejection of Books

November 4, 2025 534 Views 0 comment Print

The Jodhpur ITAT set aside a ₹ 8.13 lakh expense disallowance against Sarvodaya Mining Services. The Tribunal ruled additions cannot be made unless the assessee’s books of account are first rejected under Section 145.

ITAT Jodhpur Orders Fresh Verification as AO Ignored Accounting Method in Educational Trust Case

November 4, 2025 291 Views 0 comment Print

Tribunal found that the Assessing Officer made additions without examining whether the trust followed a cash or accrual accounting system. The matter was remanded for de novo verification to ensure fair assessment under Section 10(23C)(iiiad).

ITAT Deletes ₹19.04 Lakh Addition: Agent’s Cash Deposits Were Company Collections

November 4, 2025 837 Views 0 comment Print

ITAT Deletes ₹19.04 Lakh Addition: Agent’s Cash Deposits Were Company Collections The ITAT ruled that cash deposits of ₹19.04 lakh made by commission agent Shyam Singh Hetta were reconciled collections for his principal, DTM Pvt. Ltd., and deleted the unexplained money addition under Section 69A.

ITAT Remands Cash Deposit Case Linked to Wrong PAN for Verification

November 4, 2025 528 Views 0 comment Print

ITAT Ranchi directed the AO to readjudicate the tax liability for a ₹23.5 lakh cash deposit after the assessee claimed the bank wrongly attached his PAN to a company’s account. The AO must verify if the company disclosed the account and had adequate cash for the deposit.

PCIT Empowered to Revise Incomplete Assessments—Failure to Tax Entire Survey Disclosure Held Prejudicial to Revenue

November 4, 2025 282 Views 0 comment Print

Pune ITAT dismissed a firm’s appeal, confirming the PCIT’s order to tax Rs 19.44 lakh in unexplained cash and stock found in a survey under the stringent Section 115BBE.

Helicopter Lease Held Operating, Not Financing: Article 8 Relief Granted Under India–Ireland DTAA

November 4, 2025 666 Views 0 comment Print

The Tribunal ruled that the lease rentals received by Irish residents were exempt from tax in India under Article 8 of the treaty, following precedent on operating leases. The ruling affirms that the DTAA explicitly covers the rental of aircraft (including helicopters) in international traffic.

CPC cannot disallow 80P deduction while processing return u/s 143(1) for pre–A.Y. 2021–22 cases

November 4, 2025 777 Views 0 comment Print

The Tribunal held that the adjustment made by the CPC disallowing the co-operative society’s Section 80P claim was bad in law for pre-A.Y. 2021-22 years. The ruling confirms that for earlier years, the AO could not summarily deny this deduction through an intimation order.

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