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Clerical Error in Tax Audit Report Cannot Be Treated as Income: ITAT Deletes Addition

May 30, 2026 495 Views 0 comment Print

The Tribunal held that a bank guarantee wrongly reported as a contingent liability in the tax audit report could not be added to income when it was not claimed as an expense. It directed deletion of the ₹9.41 lakh addition made on the basis of the reporting error.

ITAT Quashes Reassessment as Section 148 Notice Was Based on Incorrect Facts & Figures

May 30, 2026 480 Views 0 comment Print

The Tribunal found that the reasons recorded for reopening contained incorrect figures and unsupported assumptions. It held that the reassessment proceedings were invalid and void ab initio due to lack of proper application of mind.

ITAT Restores 12A Registration Application as Bona Fide Error in Form Clause Cannot Defeat Claim

May 30, 2026 303 Views 0 comment Print

The Tribunal held that a trust’s application for regular registration could not be rejected solely because the wrong clause was selected in the prescribed form. It directed the authority to treat the application under the correct provision and decide it on merits.

ITAT Orders Fresh Review as On-Money Addition Was Based on Loose Sheet

May 30, 2026 354 Views 0 comment Print

The case involved additions for alleged on-money in Godhavi land transactions based on a handwritten loose sheet. The Tribunal restored the matter for fresh consideration, highlighting issues relating to evidence and assessment findings.

ITAT Quashes Section 263 Revision Because PCIT Raised New Issues Beyond SCN

May 30, 2026 225 Views 0 comment Print

ITAT Delhi held that the PCIT exceeded jurisdiction by introducing issues not mentioned in the Section 263 show-cause notice. The revision order was quashed for travelling beyond the scope of the proceedings.

Appeal Dismissed as Infructuous as Rectification Order Restored Section 80P Deduction

May 29, 2026 285 Views 0 comment Print

The ITAT dismissed the appeal after a rectification order under Section 154 granted the deduction under Section 80P and corrected the assessed income. The dispute no longer survived for adjudication.

Section 80P Deduction Disallowance Set Aside as CPC Made Adjustment Without Hearing Assessee

May 29, 2026 321 Views 0 comment Print

The ITAT held that deduction under Section 80P could not be disallowed through a unilateral adjustment under Section 143(1) without providing notice and an opportunity of hearing. The appeals were allowed.

Reassessment Held Void as AO Invoked Section 147 Instead of Section 153C

May 29, 2026 456 Views 0 comment Print

The reassessment was based on documents found during a search conducted on another person. The Tribunal held that proceedings should have been initiated under Section 153C and not under Sections 147/148, rendering the reassessment invalid.

ITAT Quashes Reassessment as Search-Based Material Required Action Under Section 153C, Not Section 148

May 29, 2026 276 Views 0 comment Print

The Tribunal held that documents relating to the assessee were found during the search of another person. It ruled that proceedings could only be initiated under Section 153C, making the reassessment under Section 148 invalid.

Appeal Dismissed as Section 143(1) Intimation Merged With Subsequent Scrutiny Assessment

May 29, 2026 354 Views 0 comment Print

The ITAT held that once an assessment order under Section 143(3) was passed, the earlier intimation under Section 143(1) merged into it. As a result, the appeal against the intimation became infructuous.

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