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ITAT Delhi

Reopening on Wrong Reason Quashed: ITAT Deletes Section 68 Addition

December 1, 2025 858 Views 0 comment Print

ITAT ruled that reopening was bad in law as reasons cited property purchases, while additions related to cash credits—showing no live nexus. The case reaffirms that reassessment must be based on specific, relevant material.

ITAT Rules Exemption Cannot Be Denied for Curable Form 10B Defect

December 1, 2025 579 Views 0 comment Print

Delhi ITAT held that non-filing of Form 10B is a curable defect and the assessee must be given an opportunity under section 139(9). Gross receipts cannot be taxed in entirety if exemptions fail.

Demonetisation Cash Deposits Not Unexplained: ₹45 Lakh Addition Deleted

December 1, 2025 645 Views 0 comment Print

The ITAT held that cash deposits recorded in books and from legitimate business sales during demonetisation cannot be treated as unexplained under Section 69A. Entire addition of ₹45.23 lakh was quashed.

TP Adjustment Under 80IA(10) Dismissed for Lack of Evidence

December 1, 2025 348 Views 0 comment Print

The Delhi ITAT upheld deletion of ₹2.57 crore TP adjustment, confirming that mere margin variations do not trigger 80IA(10) without evidence of profit manipulation. Revenue’s appeal dismissed.

Partial Doubt on Trading Losses Does Not Justify Rejection of Books: ITAT Delhi

November 30, 2025 318 Views 0 comment Print

ITAT Delhi held that partial doubts in trading segment losses cannot lead to total rejection of books under Section 145. The ruling confirms that documented losses supported by evidence must be considered.

Combined Section 153D Approval covering Multiple Years Invalid: ITAT Delhi

November 30, 2025 429 Views 0 comment Print

Because the approval was issued collectively for several years, the Tribunal found it invalid and allowed the appeal. The key takeaway is the necessity of separate approval for each year.

Farmhouse Qualifies as Residential House: Delhi ITAT Upholds Section 54F Relief

November 30, 2025 6012 Views 0 comment Print

The tribunal dismissed the revenue’s appeal, holding that the assessee was entitled to ₹2.36 crore deduction under Section 54F. Evidence showed only one residential property purchase, and farmhouse classification did not disqualify the claim.

AO’s Suspicion Not Evidence: Section 68 not Apply to Opening Balances

November 30, 2025 1170 Views 0 comment Print

Commission payments to agents were held genuine for AY 2013-14 and 2014-15. Tribunal directed deletion of disallowances as payments were backed by bank records, TDS, and recipient confirmations.

Bogus Purchases: Only 6% Profit Element Taxable: Delhi ITAT

November 30, 2025 1848 Views 0 comment Print

Delhi ITAT upholds CIT(A) order, ruling that only profit embedded in alleged bogus purchases can be taxed, not the full purchase value.

Satisfaction Note of 24.05.2021 Shifts Search-Year: ITAT Holds AY 2011-12 Outside Six-Year Block

November 30, 2025 447 Views 0 comment Print

ITAT Delhi held that AY 2011-12 is barred by limitation under Section 153C as the deemed search year started only when documents were received in 2021, nullifying the reassessment and related penalties.

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