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Section 69A Addition Deleted Due to Double Taxation of Recorded Sales

April 6, 2026 216 Views 0 comment Print

The issue involved treating cash deposits as unexplained despite being part of recorded sales. The Tribunal held that taxing the same income again results in impermissible double taxation.

Restriction to ₹3L Invalid After CBDT Raised Leave Encashment Limit to ₹25 Lakh

April 4, 2026 7185 Views 1 comment Print

The Tribunal addressed denial of leave encashment exemption restricted to ₹3 lakh. It held that the revised CBDT limit of ₹25 lakh applies, allowing full exemption within the threshold.

Dividend Stripping Disallowance Upheld as Section 94(7) Applies to Entire Dividend

April 4, 2026 534 Views 0 comment Print

The case examined whether disallowance under section 94(7) should be limited to exempt dividend. The Tribunal held that the provision applies to the full dividend received, rejecting the assessee’s claim.

Settlement of Arbitration Award on Corporate Guarantee Deductible Under Section 37(1)

April 4, 2026 300 Views 0 comment Print

The case examined whether settlement of a corporate guarantee liability qualifies as business expenditure. The Tribunal held that the guarantee was given for business purposes and the resulting payment was allowable. 

₹1.63 Crore Addition Deleted Due to Eligibility of Credit Societies Under Section 80P

April 4, 2026 234 Views 0 comment Print

The Tribunal examined whether loans for non-agricultural purposes disqualify a co-operative society from deduction under Section 80P. Relying on Supreme Court precedent, it held that such loans do not bar deduction. The ruling clarifies that credit facilities to members need not be limited to agricultural purposes.

ITAT Deletes Loss Disallowance Due to Lack of Evidence of Share Price Manipulation

April 4, 2026 414 Views 0 comment Print

The Tribunal held that disallowance of loss based on alleged penny stock manipulation was not justified without corroborative evidence. It found that transactions were supported by demat and banking records. 

Addition Under Section 40A(2)(a) Deleted Due to Incorrect Comparison of Services

April 4, 2026 360 Views 0 comment Print

The ITAT held that the Assessing Officer wrongly compared dissimilar email marketing services to determine excess payment. The ruling clarifies that only comparable services can be used for arm’s length evaluation, leading to deletion of the addition.

No 143(2) Notice, No Reassessment: ITAT Quashes Proceedings Despite Delayed ITR

April 4, 2026 750 Views 0 comment Print

The Tribunal held the assessment invalid as no mandatory notice under Section 143(2) was issued. The key takeaway is that absence of such notice renders the entire assessment void.

Penalty U/s 271(1)(c) Upheld on Bogus Purchases – ITAT Confirms Concealment

April 4, 2026 528 Views 0 comment Print

The issue was whether penalty for bogus purchases was justified. The Tribunal held that concealment through non-genuine purchases attracts penalty, confirming the levy.

Reopening for AY 2015-16 After 01.04.2021 Invalid – ITAT Quashes U/s 148 Notice as Time-Barred

April 4, 2026 1314 Views 0 comment Print

The issue was validity of reopening beyond the limitation period. The Tribunal held the notice issued after the prescribed time was invalid, and quashed the entire reassessment.

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