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ITAT Chennai

Second Reopening u/s 147 Quashed as Change of Opinion—Section 54F Deduction Cannot Be Revisited Without New Material

January 8, 2026 711 Views 0 comment Print

The issue was whether a second reassessment could be initiated on the same facts already examined earlier. The Tribunal held that reopening based on a mere change of opinion is invalid and quashed the reassessment.

Reassessment After Four Years Invalid for Change of Opinion: ITAT Chennai

January 8, 2026 525 Views 0 comment Print

The issue was whether reassessment could be initiated beyond four years after a completed scrutiny assessment. The Tribunal held that reopening was barred as there was no failure to disclose material facts.

Section 54F Exemption Cannot Be Denied for Small or Modest House Construction

January 8, 2026 5163 Views 0 comment Print

The AO denied exemption relying on an inspector’s report citing minimal construction. The Tribunal held that documentary evidence showed a habitable residence, entitling exemption.

Aggregated Cash Payments Cannot Trigger Section 40A(3) Disallowance

January 8, 2026 561 Views 0 comment Print

The ITAT held that cash expenditure cannot be disallowed merely by aggregating payments. Since no payment to any person on a single day crossed the statutory limit, the disallowance was deleted.

Section 80P Claim Sent Back as Return Delay May Be Condoned

January 8, 2026 582 Views 0 comment Print

The dispute arose from CPC denial of deduction due to late return filing. The Tribunal restored the matter, holding that the Assessing Officer must act based on the CCIT’s condonation decision.

Survey-Based Additions Set Aside Due to Lack of Effective Hearing

January 8, 2026 207 Views 0 comment Print

The ITAT held that additions based on survey material cannot be sustained without proper opportunity of hearing. The matter was remitted for fresh adjudication after finding violation of natural justice.

Section 263 Quashed as AO Examined LTCG Exemption for Insurers

January 8, 2026 276 Views 0 comment Print

The issue was whether revision could be invoked for allowing LTCG exemption on sale of investments. The Tribunal held that since the Assessing Officer examined the claim, the order was not erroneous or prejudicial.

Gold Jewellery Seized u/s 132A Held Explained – Addition u/s 69 r.w.s. 115BBE Deleted

January 8, 2026 429 Views 0 comment Print

The tribunal examined whether gold jewellery seized during police interception could be taxed as unexplained solely based on a statement recorded under enquiry. It held that additions fail where later evidence shows the assessment relied on weak corroboration and inconsistent reasoning.

Notice Issued Via ITBA After 01-04-2021 Triggers New Reopening Law

January 6, 2026 618 Views 0 comment Print

The issue was whether a notice dated 31-03-2021 but digitally signed on 01-04-2021 was valid. The ITAT held the notice was issued under the new regime without following section 148A, rendering reassessment void.

Post-2022 Reassessment Fails for Ignoring Faceless Procedure

January 6, 2026 915 Views 0 comment Print

The case examined whether reassessment proceedings could survive when issued outside the faceless mechanism. The ruling confirms that non-compliance with the faceless scheme is a fatal jurisdictional defect.

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