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Sale Deed Alone Cannot Justify Tax Addition as It Is Not Incriminating Material: ITAT Delhi

July 4, 2026 327 Views 0 comment Print

ITAT held that a registered sale deed without corroborative evidence is not incriminating material and cannot support additions in Section 153A proceedings.

Profit Already Disclosed & Taxed Cannot Be Added Again as Undisclosed Income: ITAT Delhi

July 4, 2026 165 Views 0 comment Print

ITAT held that business profit already disclosed in the income tax return cannot be added again as undisclosed income. The duplicate addition was deleted.

Section 12A Registration Cannot Be Denied for Absence of Irrevocability Clause: ITAT Delhi

July 4, 2026 177 Views 0 comment Print

ITAT held that the Commissioner must assess the genuineness of activities and charitable objects instead of rejecting registration solely for the absence of an irrevocability clause.

Cost-to-Cost Overseas Reimbursements Without Profit Element Not Taxable as FTS: ITAT Delhi

July 4, 2026 162 Views 0 comment Print

ITAT Delhi held that IT, salary and travel reimbursements without any profit element were not taxable and deleted the disallowance under Section 40(a)(i).

Section 148 Reassessment Based on Pre-2021 Third-Party Search Material Invalid; Section 153C Mandatory: ITAT Kolkata

July 4, 2026 282 Views 0 comment Print

ITAT held reassessment under Sections 147/148 invalid because it was based on a pre-1 April 2021 third-party search, requiring proceedings under Section 153C.

Section 148 Notice Issued Beyond First Proviso to Section 149 Time Limit Quashed: ITAT Mumbai

July 4, 2026 372 Views 0 comment Print

ITAT Mumbai quashed a Section 148 notice issued after the limitation under the first proviso to Section 149, holding the reassessment invalid for AY 2015-16.

Section 80G Deduction on Eligible CSR Donations Cannot Be Denied Solely Due to CSR Nature: ITAT Mumbai

July 4, 2026 126 Views 0 comment Print

ITAT Mumbai held that eligible CSR donations qualify for Section 80G deduction if statutory conditions are met, despite disallowance under Section 37(1).

Captive Service Provider Entitled to Risk Adjustment; Nil ALP for Proven Intra-Group Services Rejected: ITAT Delhi

July 4, 2026 192 Views 0 comment Print

ITAT Delhi held that documentary evidence established receipt of intra-group administrative support services and that the 5% markup was at arm’s length. The transfer pricing adjustment was accordingly deleted.

Section 80G Approval Cannot Be Denied on Technical Limitation Grounds: ITAT Surat

July 4, 2026 174 Views 0 comment Print

ITAT Surat held that existing charitable institutions obtaining provisional approval for the first time should not be denied regular approval merely because their activities commenced before the amended registration regime. The matters were remanded for fresh consideration.

ITAT Deletes Section 271AAB Penalty as SCN Not Specified Statutory Charge

July 4, 2026 222 Views 0 comment Print

ITAT Hyderabad held that a penalty notice under Section 271AAB must clearly specify the applicable statutory limb and charge. As the notice was vague and defective, the penalty proceedings were held to be invalid.

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