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ITAT Rajkot

When Professional Negligence Meets Harsh Limitation – ITAT Steps In to Protect Assessee

December 10, 2025 183 Views 0 comment Print

The Tribunal held that the assessee cannot be penalised for mistakes of his CA and condoned a two-year delay. The matter was remanded for de novo assessment, reaffirming natural justice principles.

ITAT Cuts Additions from Rs.13.91 Lakh to Rs.1.39 Lakh Using 10% Estimate

December 10, 2025 123 Views 0 comment Print

The Tribunal held that the AO found no fabricated or false documents for agricultural or tuition income. Since evidence existed but was incomplete, ITAT applied a 10% estimate and cut the addition drastically.

Tribunal Rejects Reopening Triggered by Irrelevant Information

December 9, 2025 216 Views 0 comment Print

The Tribunal held that reassessment could not stand because the recorded reasons pertained to a different assessment year. The reopening was invalid, and all related additions were rendered infructuous.

Form No. 26AS Not Equal to Turnover: Penalty u/s 271B Deleted for ₹1.11 Cr

December 3, 2025 1185 Views 0 comment Print

ITAT Rajkot held that cash reflected in 26AS represents pass-through freight receipts, not actual turnover. Commission income below the audit threshold, hence tax audit under section 44AB was not required and penalty u/s 271B deleted.

Section 144 Assessment Partly Modified: 8% Reduced to 6% NP on ₹1.99 Cr

December 3, 2025 174 Views 0 comment Print

ITAT partly allowed appeal against additions under section 144, applying 6% net profit instead of AO’s 8% on total cash deposits. Returned income under section 44AD was deducted, and normal tax rates applied instead of section 115BBE.

Land Acquisition Act Section 28 Interest is Not ‘Interest’: Tribunal Deletes Entire Addition as Capital Receipt

December 3, 2025 702 Views 0 comment Print

Tribunal holds that Section 28 interest forms part of compensation for compulsory acquisition and cannot be taxed as income from other sources. Confirms exemption under Section 10(37).

ITAT Rajkot: Wrong Sanction & Late 148 Notice Void Reassessment

December 1, 2025 567 Views 0 comment Print

Reassessment notice issued beyond statutory time limit under Section 148 was invalid; Tribunal quashed proceedings for A.Y. 2013-14, emphasizing procedural compliance.

Appeal Rejected Due to 300-Day Delay: Tribunal Refuses to Entertain 80P Deduction Claim

December 1, 2025 225 Views 0 comment Print

The ITAT held that without a condonation petition, a 300-day delay cannot be excused. The ruling underscores that delay must be justified before merits—including Section 80P—can be considered.

Section 263 Action Invalid Due to Adequate Inquiry by Assessing Officer

November 30, 2025 333 Views 0 comment Print

The Tribunal held that the revision was invalid because the assessment caused no loss to Revenue, as agricultural income was exempt and the Assessing Officer had made adequate inquiries. The order under section 263 was therefore set aside.

ITAT Partially Allows Demonetisation Cash Addition Using Reasonable Estimate

November 28, 2025 210 Views 0 comment Print

Appeal delayed by 252 days due to counsel’s oversight was condoned by ITAT citing reasonable diligence. Tribunal then reduced unexplained cash addition under Section 69A to ₹1.8 lakh using a fair estimation method.

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