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Notional Interest Addition Deleted Due to Absence of Fresh Advances & Sufficient Funds

April 1, 2026 360 Views 0 comment Print

The Tribunal held that where interest-free funds exceed investments, no disallowance is warranted. It applied the presumption that investments are made from own funds.

Section 148 Notice Invalid When Issued After Limitation Deadline: ITAT Mumbai

April 1, 2026 1506 Views 0 comment Print

Zee Entertainment Enterprises Limited Vs DCIT (ITAT Mumbai) The matter concerns two appeals filed by the assessee against orders of the Commissioner of Income Tax (Appeals)-48, Mumbai, for Assessment Years (AY) 2015–16 and 2019–20. Both appeals arise from assessment orders passed under Section 143(3) read with Section 147 of the Income Tax Act, 1961. Since […]

Section 68 Addition Upheld for Failure to Prove Genuineness of Advance: ITAT Delhi

April 1, 2026 474 Views 0 comment Print

The ITAT upheld ₹90 lakh addition as the assessee failed to establish genuineness and creditworthiness of the transaction. The ruling emphasizes the burden of proof on taxpayers in cash credit cases.

Section 263 Revision Quashed Due to Pending Appeal on Same Issue Before CIT(A)

April 1, 2026 480 Views 0 comment Print

The ITAT held that the PCIT cannot invoke revisionary powers when the same issue is already pending before the appellate authority. The case involved share transaction additions treated as penny stock. 

Reassessment Notice Invalid Due to Absence of PCCIT Approval Beyond Three Years

March 31, 2026 930 Views 0 comment Print

ITAT held that reassessment notice issued after three years without PCCIT approval violates Section 151(ii). The approval taken from PCIT was found insufficient. The ruling confirms that proper authority approval is mandatory for valid reassessment.

Section 271(1)(c) Penalty Deleted Due to Pending HC Decision on Section 10(26BBB) Exemption Claim 

March 31, 2026 270 Views 0 comment Print

ITAT upheld deletion of penalty as the exemption issue was pending before the High Court. The assessee had filed an undertaking under Section 158A. The ruling highlights that penalty cannot be sustained when the core issue is yet to be finally adjudicated.

Section 80P Deduction Claim Restored for Failure to Examine Assessee’s Legal Status & Activities

March 31, 2026 291 Views 0 comment Print

ITAT remanded the case as authorities failed to determine whether the assessee was a society, trust, or other entity. The eligibility for deduction was not properly examined. The ruling highlights the need for factual verification before denying tax benefits.

ITAT Upholds Addition as Cash Hoarding Explanation Failed Human Probability Test

March 31, 2026 384 Views 0 comment Print

The Tribunal held that the assessee failed to substantiate the source of cash deposits during demonetization. Mere disclosure in books was insufficient without proof of genuineness and credibility.

No TDS Default on LFC Payment as Bank Followed Binding HC Interim Orders

March 31, 2026 834 Views 0 comment Print

The Tribunal held that the assessee could not deduct tax due to binding interim directions of the High Court. As a result, it could not be treated as an assessee in default under Section 201.

ITAT Mumbai Quashed Reassessment Due to Wrong Assessment Year in Recorded Reasons

March 31, 2026 378 Views 0 comment Print

The Tribunal rejected reopening based on common reasons for multiple years without year-specific justification. The absence of relevant material for AY 2010–11 led to quashing of reassessment. The ruling stresses precision in reopening proceedings.

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