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Income Tax Section 143(1) Adjustments Without Opportunity of Hearing Unsustainable

April 14, 2026 540 Views 0 comment Print

The Tribunal held that adjustments made without issuing prior notice to the assessee violate the mandatory proviso to Section 143(1)(a). Such actions were declared legally unsustainable and liable to be deleted.

ITAT Delhi Allows TDS Credit as CPC Failed to Issue Mandatory Notice

April 14, 2026 324 Views 0 comment Print

The Tribunal held that CPC cannot make adjustments without issuing prior notice under Section 143(1)(a). The disallowance of TDS credit was set aside for lack of jurisdiction.

Additional Evidence Rejected Due to Violation of Income Tax Rule 46A Procedures

April 14, 2026 720 Views 0 comment Print

The Tribunal held that the CIT(A) improperly admitted additional evidence without satisfying Rule 46A conditions or recording reasons. It emphasized that procedural compliance is mandatory and failure to follow it invalidates the relief granted.*

ITAT Mumbai: No Penalty U/s 271(1)(c) on Estimated Bogus Purchase Additions

April 13, 2026 507 Views 0 comment Print

The Tribunal held that penalty under Section 271(1)(c) cannot be imposed when additions are made on an estimated basis. It upheld deletion of penalty, emphasizing absence of concrete evidence of concealment.

ITAT Mumbai: Sec 54 Claim Cannot Be Denied Merely for No Original Return-Allowed in Reassessment

April 13, 2026 720 Views 0 comment Print

The Tribunal clarified that filing of original return is not mandatory for claiming exemption under Section 54. It directed verification of conditions and allowed relief if eligibility is established.

ITAT Mumbai: On-Money Addition Based on Third-Party Evidence Excel Sheets Deleted

April 13, 2026 762 Views 0 comment Print

The Tribunal held that additions based solely on third-party statements and Excel sheets are unsustainable without independent evidence. It emphasized that denial of cross-examination violates natural justice and invalidates the addition.

Third-Party Excel Sheets & Statements Without Corroboration Have No Evidentiary Value

April 13, 2026 519 Views 0 comment Print

ITAT Mumbai deletes Section 69 additions holding that third-party excel sheets and statements without corroborative evidence lack evidentiary value. Reopening based on unverified data and denial of cross-examination violates natural justice; entire additions quashed.

ITAT Bangalore: Mere Wrong Claim u/s 54 Does Not Attract Penalty u/s 271(1)(c)

April 13, 2026 324 Views 0 comment Print

The case examines whether penalty applies when a deduction claim is disallowed. ITAT held that full disclosure and bona fide claim prevent penalty under Section 271(1)(c).

Reassessment Invalid Due to Change of Opinion on Same Facts: ITAT Mumbai

April 13, 2026 357 Views 0 comment Print

The Tribunal held that reopening an assessment on identical material already examined is invalid. It ruled that reassessment cannot be used to revisit concluded issues without fresh evidence.

ITAT Mumbai: No Section 56(2)(x) Addition if Difference Within 10%-Tolerance Limit Held Retrospective

April 13, 2026 384 Views 0 comment Print

The case examined whether minor valuation differences can trigger taxation under Section 56(2)(x). ITAT held that differences within 10% fall within permissible tolerance. The ruling protects genuine transactions from arbitrary additions.

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