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ITAT Bangalore

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CIT(A) Cannot Admit Fresh Evidence Without AO’s Opportunity – Violation of Rule 46A; Matter Remanded

March 13, 2026 60 Views 0 comment Print

The Tribunal ruled that admitting additional evidence without seeking a remand report from the Assessing Officer breaches Rule 46A. The matter was sent back to the AO for reconsideration after examining the evidence.

Delay in Filing Form 9A & Return Should Be Considered for Condonation; Matter Remanded for Fresh Examination

March 13, 2026 159 Views 0 comment Print

ITAT held that delay in filing Form 9A cannot automatically result in denial of exemption under Section 11. The issue was sent back for reconsideration after examining the condonation application before the Commissioner.

Reassessment Quashed – Notice U/s 148A(b) Invalid for Granting Less Than Mandatory 7 Days to Reply

March 13, 2026 201 Views 0 comment Print

The Tribunal ruled that Section 148A(b) requires a minimum of seven days for the assessee to respond. Failure to grant this statutory period renders the notice and subsequent reassessment proceedings illegal.

Bogus Purchase Addition Deleted – Suspicion from STR Report Insufficient When Purchases Supported by Evidence

March 13, 2026 303 Views 0 comment Print

ITAT Bangalore held that the Assessing Officer must establish bogus purchases with cogent evidence before making additions. Since the assessee produced complete records and the AO found no defects, the entire addition was deleted.

Reassessment Quashed as Time-Barred – Fresh Notice U/s 148 Issued Beyond Surviving Period After Ashish Agarwal Judgment

March 13, 2026 201 Views 0 comment Print

The Tribunal found that the Assessing Officer failed to issue the fresh notice within the surviving limitation period recognized by the Supreme Court. The reassessment order was therefore quashed.

Reassessment Quashed – Mechanical Approval U/s 151 Based on Wrong Fact that Assessee Was a Non-Filer

March 13, 2026 165 Views 0 comment Print

ITAT Bangalore held that reassessment proceedings were invalid where approval under Section 151 was granted mechanically. The sanction was based on the incorrect assumption that the assessee had not filed a return.

PCIT Can Invoke Revision U/s 263 Based on Subsequent SC Decision; DRP-Based Assessment Also Revisable

March 13, 2026 63 Views 0 comment Print

The Tribunal ruled that an assessment order passed after DRP directions is still subject to revision under Section 263. It held that there is no statutory bar preventing the Principal Commissioner from revising such orders.

Common Satisfaction Note for Multiple AYs Invalid U/s 153C: ITAT Bangalore

March 12, 2026 333 Views 0 comment Print

The case addressed whether tax authorities can issue notices for multiple years based on one satisfaction note. The tribunal ruled that each assessment year requires an independent satisfaction linking seized material.

When Adjustment u/s 143(1) Is Deleted in Appeal, Assessment Based on Such Adjustment Cannot Survive: ITAT Bangalore

March 12, 2026 1767 Views 0 comment Print

The Tribunal held that when an adjustment made in the CPC intimation is subsequently deleted in appeal, the scrutiny assessment relying on that adjustment cannot continue. The income was therefore restored to the amount originally declared by the assessee.

Assessment in the Name of Deceased Person – Absence of Notice to Legal Heir – Entire Assessment Held Void: ITAT Bangalore

March 12, 2026 3336 Views 0 comment Print

Despite disputes over agricultural income additions, the Tribunal focused on the legality of the proceedings. It held that issuing a notice to a deceased taxpayer is a substantive illegality and cannot be treated as a curable procedural defect. The assessment was quashed.

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