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ITAT Delhi

Abandoned Business Project Expenses Allowed as Deduction Due to Business Purpose

April 14, 2026 1101 Views 0 comment Print

Expenses incurred for a proposed business project later abandoned were allowed as revenue expenditure. The Tribunal held that such costs remain deductible if incurred for business purposes.

CPC Section 143(1) Adjustment Invalid if done without Prior Intimation: ITAT Delhi

April 14, 2026 450 Views 0 comment Print

The Tribunal ruled that failure to issue prior notice before making adjustments violates the mandatory provisions of Section 143(1)(a). Such procedural lapse renders the entire adjustment legally unsustainable.

Income Tax Section 143(1) Adjustments Without Opportunity of Hearing Unsustainable

April 14, 2026 537 Views 0 comment Print

The Tribunal held that adjustments made without issuing prior notice to the assessee violate the mandatory proviso to Section 143(1)(a). Such actions were declared legally unsustainable and liable to be deleted.

ITAT Delhi Allows TDS Credit as CPC Failed to Issue Mandatory Notice

April 14, 2026 315 Views 0 comment Print

The Tribunal held that CPC cannot make adjustments without issuing prior notice under Section 143(1)(a). The disallowance of TDS credit was set aside for lack of jurisdiction.

Additional Evidence Rejected Due to Violation of Income Tax Rule 46A Procedures

April 14, 2026 711 Views 0 comment Print

The Tribunal held that the CIT(A) improperly admitted additional evidence without satisfying Rule 46A conditions or recording reasons. It emphasized that procedural compliance is mandatory and failure to follow it invalidates the relief granted.*

Addition u/s 68 was unsustainable without rebuttal of NBFC genuineness or tracing money trail

April 13, 2026 447 Views 0 comment Print

Addition under Section 68 could not be sustained where assessee has established the genuineness of a Non-banking financial company (NBFC) investor, and the AO failed to rebut such evidence or trace any money trail linking the assessee to the invested funds.

Income Tax Assessment Quashed Due to Invalid Notice by Officer Lacking Pecuniary Jurisdiction

April 13, 2026 2898 Views 0 comment Print

The Tribunal admitted a new legal ground and held that jurisdictional defects can be raised at any stage. It quashed the assessment as the initial notice itself was issued without authority.

Can WhatsApp Chats Alone Justify Tax Additions? Tribunal Says No

April 13, 2026 1110 Views 0 comment Print

The ruling clarifies that unauthenticated digital chats and screenshots cannot form the sole basis of tax additions without proper verification and legal compliance.

ITAT Delhi Invalidates 153C Proceedings Because Satisfaction Note Lacked Income Link

April 10, 2026 330 Views 0 comment Print

ITAT held that failure to record how seized material impacts taxable income invalidates proceedings. All assessments were quashed due to defective satisfaction note.

Undisclosed Income Additions Quashed as Revenue Failed to Corroborate Diary Entries

April 10, 2026 1794 Views 0 comment Print

The case examined whether documents found during search can be automatically attributed to the assessee. The Tribunal ruled that ownership and connection must be established through evidence. The decision underscores limits of statutory presumptions under Section 292C.

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