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Section 40A(3) Addition Quashed as Department Failed to Prove Single-Day Violation

June 17, 2026 213 Views 0 comment Print

The Tribunal deleted the disallowance after finding no evidence that cash rent payments exceeded ₹10,000 on any single day. The ruling underscores that Section 40A(3) cannot be invoked without establishing an actual breach of the prescribed limit.

Section 50C Addition Upheld as Seized Cash Confirmed On-Money Receipt

June 17, 2026 294 Views 0 comment Print

ITAT sustained the adoption of fair market value under Section 50C after finding that seized cash represented on-money from property transactions. The Tribunal upheld the valuation determined through the DVO process.

ITAT Condones 311-Day Delay & Remands Reassessment Due to Need for Fresh Evidence

June 17, 2026 192 Views 0 comment Print

ITAT Chennai condoned a 311-day delay in filing the appeal and restored the matter for fresh adjudication. The Tribunal held that the assessee should receive one final opportunity to explain the source of cash deposits with supporting documents.

Indexed Cost of Construction Must Be Allowed as Building Details Were Part of Sale Deed: ITAT Chennai

June 17, 2026 183 Views 0 comment Print

ITAT Chennai held that indexation on construction cost cannot be denied when details of the building are already contained in the registered sale deed and its annexure. The Tribunal directed recomputation of capital gains after allowing indexed construction cost.

Reopening Upheld as Seized Diaries Revealed Unaccounted Cash Transactions Above Statutory Threshold

June 17, 2026 159 Views 0 comment Print

ITAT Ahmedabad upheld reassessment proceedings after finding that seized diaries recorded unaccounted cash transactions exceeding prescribed limits. The Tribunal held that statutory conditions for reopening were satisfied.

ITAT Quashes U/s 153C Assessments: AO Cannot Simply Copy Satisfaction Note

June 17, 2026 183 Views 0 comment Print

The Tribunal ruled that Section 153C requires the AO of the other person to independently assess whether seized documents have a bearing on that person’s income. A mechanical satisfaction note based solely on another officer’s communication was held invalid.

Reopening Quashed: AO Added Share Capital, Loan & Premium Without Understanding Transaction Nature

June 17, 2026 111 Views 0 comment Print

Jaipur ITAT held that reassessment proceedings were invalid because the Assessing Officer mechanically relied on Investigation Wing information without conducting independent verification.

WhatsApp Chats, Screenshots & Suspicion Can’t Prove On-Money: ITAT Jaipur

June 17, 2026 2499 Views 0 comment Print

The Tribunal ruled that third-party WhatsApp messages and decoded chat entries lacked evidentiary value against the assessee without corroborative material. The Revenue failed to prove that any cash was actually paid over and above the registered sale consideration.

ITAT Directs TDS Refund Despite Delayed E-Verification; Revenue Cannot Retain Tax on Technical Grounds

June 17, 2026 417 Views 0 comment Print

The Tribunal ruled that technical lapses in e-verification cannot override a taxpayer’s lawful entitlement to a refund. Once the delay was condoned and the return accepted, denial of the refund was held unjustified.

ITAT Quashes Reassessment: Approval from PCIT Instead of PCCIT Renders Section 148 Notice Invalid

June 17, 2026 285 Views 0 comment Print

The Tribunal ruled that reopening proceedings cannot survive where the mandatory sanction under Section 151 is not obtained from the prescribed authority. The defect was held to be jurisdictional, rendering the notice invalid.

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