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ITAT Delhi

No Additions Without Specific Incriminating Material: ITAT Delhi

September 11, 2025 336 Views 0 comment Print

ITAT Delhi dismisses Revenue’s appeals, affirming CIT(A)’s decision to reduce commission income estimation for SNW Smith Consultants Pvt. Ltd. based on group settlement and lack of specific incriminating material.

Section 148 Notice Time-Barred, Reassessment Void Ab Initio: ITAT Delhi

September 11, 2025 438 Views 0 comment Print

ITAT Delhi rules a reassessment void, holding that the Section 148 notice was issued beyond the statutory limitation period, citing Supreme Court and High Court precedents.

ITAT Delhi Quashes Search Assessments Over Mechanical 153D Approval

September 11, 2025 504 Views 0 comment Print

ITAT Delhi quashes search assessments, ruling that a consolidated approval under Section 153D for multiple years is invalid and demonstrates a lack of independent application of mind.

Common & Ritualistic Section 153D Approval renders Assessment Void

September 11, 2025 486 Views 0 comment Print

The ITAT Delhi quashes search assessments against Minda Corporation, ruling that a mechanical, consolidated approval under Section 153D was invalid and failed to meet statutory requirements.

Reassessment based on mechanical 148A(d) order without speaking reasons invalid

September 11, 2025 696 Views 0 comment Print

ITAT Delhi rules reassessment invalid, stating the Assessing Officer’s failure to provide a speaking order under Section 148A(d) was a violation of mandatory statutory procedures.

Unreal Interest Income Cannot Be Taxed – ITAT Delhi Deletes ₹3.60 Cr Addition

September 11, 2025 234 Views 0 comment Print

ITAT Delhi deletes a Rs.3.60 crore addition to income, ruling that unrealized interest cannot be taxed and that a fraudulent TDS return does not constitute actual income.

Section 68/115BBE Not Applicable on Recorded Cash Sales – ITAT Deletes ₹7.04 Cr Addition

September 11, 2025 741 Views 0 comment Print

ITAT Delhi rules recorded cash sales are not unexplained income under Section 68, preventing double taxation, even during demonetization, if books are accepted.

Under-reporting vs Misreporting Confusion Fatal to Section 270A Penalty: ITAT Delhi

September 11, 2025 1419 Views 0 comment Print

The ITAT Delhi deleted a penalty levied under Section 270A against Kanodia Technoplast, ruling that the penalty order was invalid for failing to specify the nature of the offense.

Manual Form 10 Filing Before Due Date Valid: ITAT deletes Rs.25.5 lakh addition

September 11, 2025 381 Views 0 comment Print

The ITAT Delhi ruled that an Assessing Officer could not disregard the Tribunal’s prior order regarding the manual vs. electronic filing of Form 10, deleting the disallowance.

ITAT Delhi Upholds External Development Charges Interest as Revenue Expense

September 11, 2025 690 Views 0 comment Print

The ITAT Delhi dismissed the revenue’s appeal, ruling that interest on External Development Charges (EDC) is a deductible revenue expense, not a penal or capital one.

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