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ITAT Delhi

ITAT Delhi Set Aside Bogus Purchase Addition for Breach of Section 250(6)

January 13, 2026 840 Views 0 comment Print

The issue was whether the appellate order properly dealt with bogus purchase additions. ITAT held that a non-speaking NFAC order violating section 250(6) must be set aside.

Depreciation on Intangible Highway Assets Allowed: ITAT Delhi

January 13, 2026 360 Views 0 comment Print

The issue was whether depreciation can be claimed on BOT road projects. ITAT upheld depreciation, rejecting mere amortisation under the CBDT circular.

TDS Credit Allowable Despite Capitalised Interest Reduction from CWIP: ITAT Delhi

January 13, 2026 618 Views 0 comment Print

The issue was whether TDS credit can be denied when interest income is adjusted against capital work-in-progress. ITAT held that once income is indirectly recognised by reducing CWIP, corresponding TDS credit cannot be refused.

Mechanical Section 153D Approval Quashes Search Assessments: ITAT Delhi

January 13, 2026 381 Views 0 comment Print

The issue was whether common and ritualistic approval under section 153D can sustain search assessments. ITAT held that mechanical approval without independent application of mind vitiates the entire proceedings.

Reassessment Notice Time-Barred Under Section 149, ITAT Quashes Case

January 13, 2026 900 Views 0 comment Print

The issue was whether a reassessment notice issued after 31.03.2021 for AY 2014-15 was within limitation. ITAT held the notice time-barred in light of the Supreme Court’s Rajeev Bansal ruling and quashed the entire reassessment.

Section 148 Reopening Notice Issued Late is Invalid: ITAT Delhi

January 13, 2026 453 Views 0 comment Print

It was ruled that a reassessment notice issued after expiry of the extended limitation is void. The takeaway is that delayed action under the new reassessment regime is fatal.

Illegal Section 143(2) Notice Vitiates Search-Based Assessment

January 13, 2026 597 Views 0 comment Print

The notice under section 143(2) did not conform to the CBDT-prescribed format. ITAT ruled that a defective notice strikes at jurisdiction and invalidates the assessment.

Section 263 Cannot Expand Beyond Limited Scrutiny Scope: ITAT Delhi

January 13, 2026 411 Views 0 comment Print

The Tribunal held that revision under section 263 cannot introduce issues outside the original limited scrutiny mandate. The key takeaway is that the PCIT cannot widen the inquiry beyond CASS-selected parameters.

No Double Tax on Cash Sales Recorded in Books: ITAT Delhi

January 13, 2026 621 Views 0 comment Print

The Tribunal held that cash deposits arising from genuine sales already recorded in books cannot be taxed again as unexplained money. The key takeaway is that such additions amount to impermissible double taxation.

Section 50C Adjustment Barred at Return Processing Stage: ITAT Delhi

January 13, 2026 756 Views 0 comment Print

It was ruled that substituting sale consideration with stamp duty value during CPC processing is impermissible. Such action deprives taxpayers of the statutory right to seek DVO valuation.

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