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ITAT Delhi

Partial Disallowance Upheld as Assessee Failed to Prove Full Business Nexus of Expenses

April 10, 2026 216 Views 0 comment Print

The case involved disallowance of business expenses where activity was minimal. ITAT held that existence of even limited business justified partial allowance and restricted disallowance to ₹1 lakh.

CPC Cannot Reduce TDS Credit Based on Turnover Differences in 26AS: ITAT Delhi

April 10, 2026 3465 Views 0 comment Print

The issue involved restriction of TDS credit due to mismatch between Form 26AS and return. ITAT held that such adjustments require verification and cannot be made under Section 143(1).

Assessment order void as approval u/s. 153D granted in mechanical manner without application of mind

April 9, 2026 366 Views 0 comment Print

ITAT Delhi held that granting of mandatory approval under section 153D of the Income Tax Act by Additional Commissioner of Income Tax in a mechanical manner and without due application of mind is an empty ritual. Thus, order held void-abinitio for want of valid approval u/s. 153D.

AMP expense incurred exclusively for business is revenue expenditure: ITAT Delhi

April 8, 2026 282 Views 0 comment Print

ITAT Delhi held that Advertisement, Marketing & Promotion expense [AMP expense] incurred by Make My Trip wholly and exclusively for the business is not capital in nature. Further, since AMP expense is not an international transaction, adjustment by TPO rightly deleted.

ITAT Delhi Reduces Cash Deposit Addition to 5% Due to Lack of Evidence by AO

April 7, 2026 555 Views 0 comment Print

The Tribunal held that additions based on presumptions without evidence cannot be sustained fully. It reduced the addition on unexplained cash deposits from 10% to 5%, granting relief to the assessee.

Section 54 Exemption Allowed Without Registration Due to Possession & Payment

April 7, 2026 735 Views 0 comment Print

The Tribunal held that exemption cannot be denied merely because the purchase agreement was unregistered. Substantial payment and possession were considered sufficient for claiming relief.

Section 54 Deduction Allowed for Multiple Floors Due to Single Residential House Interpretation

April 7, 2026 597 Views 0 comment Print

The Tribunal held that different floors of the same building constitute one residential house. Deduction under Section 54 cannot be denied on the ground of structural division.

Restriction to ₹3L Invalid After CBDT Raised Leave Encashment Limit to ₹25 Lakh

April 4, 2026 7170 Views 1 comment Print

The Tribunal addressed denial of leave encashment exemption restricted to ₹3 lakh. It held that the revised CBDT limit of ₹25 lakh applies, allowing full exemption within the threshold.

Settlement of Arbitration Award on Corporate Guarantee Deductible Under Section 37(1)

April 4, 2026 300 Views 0 comment Print

The case examined whether settlement of a corporate guarantee liability qualifies as business expenditure. The Tribunal held that the guarantee was given for business purposes and the resulting payment was allowable. 

Addition Under Section 40A(2)(a) Deleted Due to Incorrect Comparison of Services

April 4, 2026 360 Views 0 comment Print

The ITAT held that the Assessing Officer wrongly compared dissimilar email marketing services to determine excess payment. The ruling clarifies that only comparable services can be used for arm’s length evaluation, leading to deletion of the addition.

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