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ITAT Bangalore

ITAT Bangalore Rejected Estimated Profit as Audited Books Showed Reasonable Margin

January 12, 2026 870 Views 0 comment Print

The Tribunal ruled that estimating higher profit without rejecting audited books or finding major defects is impermissible. The declared 7% margin was accepted as reasonable, emphasizing limits on ad-hoc profit estimation.

Seized Loose Papers Can Justify Section 69C Additions

January 10, 2026 618 Views 0 comment Print

The issue was whether additions can rest on seized loose sheets termed as dumb documents. The Tribunal upheld Section 69C additions, holding that seized material supported by statements is valid evidence.

Assessment Framed on Deceased Assessee Is Void Ab Initio

January 10, 2026 756 Views 0 comment Print

The issue was whether an assessment can continue after the assessee’s death. The Tribunal held such an order void ab initio when the legal heir is not substituted.

Wrong Email Service Vitiates Ex-Parte Appellate Order: ITAT Bangalore

January 9, 2026 309 Views 0 comment Print

The appeal was dismissed ex-parte due to alleged non-compliance by the assessee. The ITAT found that notices were issued to the wrong email despite correct details on record and ordered de novo consideration.

Order Giving Effect Cannot Be Challenged Directly Before ITAT

January 9, 2026 1221 Views 0 comment Print

The assessee challenged denial of Section 80P deduction in the order giving effect to the CIT(A)’s directions. The Tribunal ruled that Section 253 permits appeal only against CIT(A) orders, not against implementation orders.

Section 12AB Registration Rejected Without Hearing Set Aside

January 9, 2026 1038 Views 0 comment Print

The issue was whether final registration could be denied without granting a proper opportunity of hearing. The Tribunal held that rejection without a show-cause notice violates natural justice and remanded the matter for fresh consideration.

No Corroboration, No Tax: Diary-Based Search Additions Deleted

January 3, 2026 1062 Views 0 comment Print

Additions under section 153A were deleted as they rested only on an unowned diary without proof of authorship or corroborative evidence. The ruling reinforces that suspicion cannot substitute proof in search cases.

Wrong Route Chosen: Section 147 Fails Where 153C Alone Applies

January 2, 2026 1101 Views 0 comment Print

The Tribunal held that reassessment under section 147 fails when seized search material exists. The correct and exclusive route is section 153C, making the reopening jurisdictionally invalid.

Internal Government Process No Ground for Delay Condonation

January 2, 2026 432 Views 0 comment Print

The Tribunal held that delays caused by internal approvals from senior officials cannot justify late filing. Lack of due diligence by officials led to outright dismissal of the appeal.

Reassessment Revived Due to Cash Deposits, But With ₹25,000 Cost

January 2, 2026 381 Views 0 comment Print

The Tribunal ruled that taxing entire bank cash deposits under section 69A without examining business explanations is unsustainable. The reassessment was restored for de-novo adjudication with conditions.

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