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ITAT Bangalore

Entire Sale Value Can’t Be Added as Unexplained Cash Under 69A

January 2, 2026 753 Views 0 comment Print

The Tribunal held that once sale receipts are accepted as consideration from immovable property, they cannot be taxed as unexplained money under section 69A. The assessment was remanded for fresh adjudication on merits.

Revenue Barred From Reopening JDA Taxability Once Issue Is Settled

January 2, 2026 447 Views 0 comment Print

The Tribunal dismissed the Revenue’s appeal, holding that JDA-related income issues had already attained finality. Any attempt to reassess the same income in an earlier year would result in impermissible double taxation.

Assessment Quashed for Failure to Issue Mandatory Show Cause Notice

January 1, 2026 1983 Views 0 comment Print

The Tribunal held that additions made without issuing a mandatory show-cause notice violate CBDT instructions and natural justice. Key takeaway: Procedural compliance is essential for valid assessments.

Cash Deposit Deletion Without Source Check Fails, Matter Remanded

December 31, 2025 414 Views 0 comment Print

The assessee neither filed returns nor responded to statutory notices, yet additions were deleted on appeal. ITAT held that absence of verification of source and compliance makes such deletion unsustainable.

Clerical Error in Accounts Triggers Fresh Probe of Cash Deposit

December 31, 2025 354 Views 0 comment Print

The assessment proceeded on a fundamentally incorrect factual premise regarding the date of deposit. ITAT ruled that such an error warrants remand for fresh examination of cash source and sales genuineness.

No Profit Motive, No Denial: Section 12AB & 80G Matters Reopened

December 31, 2025 315 Views 0 comment Print

The association’s surplus was not distributable to members and activities were non-profit. The ITAT ruled that these factors support charitable character and restored the case for re-evaluation.

Sales in Books Accepted, But ‘Cash Buyer’ Bills Trigger Remand

December 31, 2025 192 Views 0 comment Print

Demonetisation-era jewellery sales were questioned as invoices mentioned buyers only as cash. The ITAT remanded the matter to verify buyer identity, stock linkage, and genuineness before sustaining any addition.

Section 263 Quashed as AO Took a Plausible View on 80P Deduction

December 31, 2025 333 Views 0 comment Print

The revision questioned deduction on interest income allowed under section 80P. The Tribunal held that where the AO adopts a legally plausible view after enquiry, section 263 cannot be invoked.

Wrong Authority Approval Invalidates Reopening Beyond Three Years

December 30, 2025 474 Views 0 comment Print

The Tribunal ruled that where more than three years have elapsed, sanction must come from the Principal Chief Commissioner. Approval by the Principal Commissioner renders the reassessment void ab initio.

JDA Advances Not Taxable as Business Income Where No Transfer under Section 2(47): ITAT Bangalore

December 25, 2025 483 Views 0 comment Print

The Tribunal held that advances received under a joint development agreement are not taxable as business income when land remains a capital asset and no transfer under section 2(47) has occurred.

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