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ITAT Delhi

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Section 9(1)(vii) FTS Addition Set Aside; Taxability Must Be Examined Under Relevant DTAA: ITAT Delhi

July 5, 2026 333 Views 0 comment Print

ITAT Delhi held legal services are not FTS under Section 9(1)(vii) and directed partner-wise DTAA examination. FTS addition was deleted and remanded.

Section 80P(2)(d) Deduction Allowed on Interest & Dividend From Co-op Banks: ITAT Delhi

July 5, 2026 81 Views 0 comment Print

ITAT Delhi held that interest and dividend earned from co-operative banks qualify for deduction under Section 80P(2)(d). Totgar’s ruling was held inapplicable on the facts.

Circle Rate-Based Land Valuation Accepted for Section 56(2)(viib) FMV: ITAT Delhi

July 5, 2026 111 Views 0 comment Print

ITAT Delhi held that circle rate-based land valuation is valid for determining FMV under Section 56(2)(viib) and deleted the addition following its earlier order.

Section 153C Assessment Quashed for Defective Consolidated Satisfaction Note: ITAT Delhi

July 5, 2026 102 Views 0 comment Print

ITAT Delhi quashed a Section 153C assessment, holding that a consolidated and defective satisfaction note invalidated jurisdiction and the assessment.

Section 68 Inapplicable to Sale Proceeds of Disclosed Investments: ITAT Delhi

July 4, 2026 225 Views 0 comment Print

ITAT Delhi held Section 68 cannot apply to sale proceeds of disclosed investments already recorded in books. Revenue’s appeals were dismissed.

Section 68 Addition on Sale of Previously Disclosed Shares Deleted to Avoid Double Taxation: ITAT Delhi

July 4, 2026 210 Views 0 comment Print

ITAT Delhi held Section 68 inapplicable where shares were disclosed in an earlier year and sale proceeds were already offered as income, avoiding double taxation.

Amalgamation Goodwill Eligible for Depreciation; Notional Interest on AE Receivables Deleted: ITAT Delhi

July 4, 2026 108 Views 0 comment Print

ITAT held that goodwill arising on amalgamation qualifies as a depreciable intangible asset. It also deleted the TP adjustment on overdue AE receivables.

Negative Cash Balance Alone Cannot Be Treated as Undisclosed Income: ITAT Delhi

July 4, 2026 324 Views 0 comment Print

ITAT held that negative cash balances do not automatically establish undisclosed income and upheld addition only to the peak negative balance.

Abandoned Project Expenses & Lease Rent Allowable as Revenue Expenditure: ITAT Delhi

July 4, 2026 69 Views 0 comment Print

ITAT held that expenditure on a permanently abandoned project is deductible as revenue expenditure and deleted the related additions.

Section 153C Limitation Begins from Receipt of Seized Material by JAO: ITAT Delhi

July 4, 2026 114 Views 0 comment Print

ITAT held that the limitation under Section 153C must be reckoned from the date the jurisdictional AO receives seized material, not the search date.

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