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ITAT Chandigarh

Big Dividend, Real Costs: ITAT Upholds Rule 8D Disallowance

December 29, 2025 237 Views 0 comment Print

The ITAT held that earning significant exempt dividend income necessarily involves indirect administrative expenses. In the absence of separate books, the AO rightly applied Rule 8D to compute disallowance.

Pre-Demonetisation Withdrawals Can Explain Post-Ban Cash Deposits

December 29, 2025 453 Views 0 comment Print

The issue was whether demonetisation-era deposits could be taxed despite admitted prior withdrawals. ITAT held that when withdrawals are genuine and the occasion is real, section 69A cannot be applied on presumptions.

Final assessment order u/s. 153A without issuance of draft assessment order u/s. 144C is void

December 27, 2025 792 Views 0 comment Print

ITAT Chandigarh held that passing of final assessment order under section 153A of the Income Tax Act without issuing draft assessment orders under section 144C of the Income Tax Act is untenable. Accordingly, final assessment order u/s. 153A is quashed.

Revision u/s. 263 for non-verification of notional interest not justified as it is taxable only on maturity

December 26, 2025 450 Views 0 comment Print

ITAT Chandigarh held that initiation of revisionary proceeding under section 263 of the Income Tax Act for non-verification of notional interest cannot be justified since notional interest is not liable to be taxed in current year but is taxable only upon maturity hence there cannot be any evasion of tax.

Capital Gains Taxable Despite Gram Panchayat Certificate When Land Is Within 8 km of Municipality

December 25, 2025 921 Views 0 comment Print

The Tribunal examined whether agricultural land qualified as a non-capital asset and upheld taxation after finding it within the prescribed municipal distance. The ruling reiterates that physical verification and reliable evidence prevail over unsupported certificates.

Same-Day Cash Withdrawal and Deposit Not Unexplained Income

December 22, 2025 699 Views 0 comment Print

The ITAT held that cash redeposited after a clearly documented bank withdrawal cannot be treated as unexplained. The ruling emphasizes that verifiable fund movement defeats section 69A additions.

Bogus Purchase Disallowance Deleted Due to Valid GST and Supporting Evidence

December 22, 2025 1350 Views 0 comment Print

The Tribunal held that purchases supported by invoices, e-way bills, banking payments, and valid GST registration at the time of supply cannot be treated as bogus. Subsequent GST cancellation and non-response by suppliers were held insufficient to justify disallowance.

No U/s 153A Addition, But Reassessment Power Explicitly Preserved

December 22, 2025 336 Views 0 comment Print

The ITAT corrected its earlier order after noting that the liberty to reopen completed assessments under sections 147/148 was omitted. The ruling clarifies that absence of incriminating material bars search additions but not lawful reassessment.

Tribunal Allows Section 12AB Registration Renewal for Public Trust

December 15, 2025 705 Views 0 comment Print

The Tribunal held that income assessment issues cannot prevent granting registration under section 12AB, directing the renewal for a trust already registered under 12AA.

Reassessment Quashed Due to Non-Compliance with Tribunal Directions

December 15, 2025 378 Views 0 comment Print

The assessee alleged denial of opportunity and improper handling of evidence. The Tribunal agreed that the appellate order was passed without due consideration of records and remand findings. The matter was sent back for fresh adjudication in accordance with law.

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