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ITAT Mumbai

Notional Interest Addition Deleted Due to Absence of Fresh Advances & Sufficient Funds

April 1, 2026 354 Views 0 comment Print

The Tribunal held that where interest-free funds exceed investments, no disallowance is warranted. It applied the presumption that investments are made from own funds.

Section 148 Notice Invalid When Issued After Limitation Deadline: ITAT Mumbai

April 1, 2026 1503 Views 0 comment Print

Zee Entertainment Enterprises Limited Vs DCIT (ITAT Mumbai) The matter concerns two appeals filed by the assessee against orders of the Commissioner of Income Tax (Appeals)-48, Mumbai, for Assessment Years (AY) 2015–16 and 2019–20. Both appeals arise from assessment orders passed under Section 143(3) read with Section 147 of the Income Tax Act, 1961. Since […]

No TDS Default on LFC Payment as Bank Followed Binding HC Interim Orders

March 31, 2026 831 Views 0 comment Print

The Tribunal held that the assessee could not deduct tax due to binding interim directions of the High Court. As a result, it could not be treated as an assessee in default under Section 201.

ITAT Mumbai Quashed Reassessment Due to Wrong Assessment Year in Recorded Reasons

March 31, 2026 378 Views 0 comment Print

The Tribunal rejected reopening based on common reasons for multiple years without year-specific justification. The absence of relevant material for AY 2010–11 led to quashing of reassessment. The ruling stresses precision in reopening proceedings.

Post-Search, AO Cannot Use Section 147 – Reassessment Quashed as Void

March 31, 2026 585 Views 0 comment Print

The issue was whether reassessment under Section 147 is valid after a search. The ITAT held it invalid, ruling that only Section 153A applies post-search, making the reassessment void.

Delay in Form 10AB Not Fatal – ITAT Favors Substantive Justice in U/s 80G Approval

March 31, 2026 417 Views 0 comment Print

The Tribunal held that delay in filing Form 10AB cannot alone justify rejection of 80G approval. It directed reconsideration on merits, emphasizing genuine charitable activity over procedural lapses.

Invalid 143(2) Notice by Wrong Officer Nullifies Entire Assessment

March 31, 2026 504 Views 0 comment Print

The Tribunal held that a notice under Section 143(2) issued by an unauthorized officer renders the entire assessment invalid. It ruled that jurisdictional defects cannot be cured and quashed the assessment.

Bogus Purchases: Only Profit Element Taxable – ITAT Reworks Addition Based on Industry Margins

March 31, 2026 1011 Views 0 comment Print

The Income Tax Appellate Tribunal held that entire bogus purchases cannot be added when sales are accepted. The only the profit element embedded in such purchases is taxable.

Section 263 Invalid as AO Conducted Inquiry on CSR Deduction Claim

March 31, 2026 252 Views 0 comment Print

ITAT held that revision under Section 263 cannot be invoked when the Assessing Officer has already examined the issue. The ruling emphasizes that mere disagreement with enquiry results does not justify revision.

Penny Stock Share Transactions: Reassessment Quashed for Change of Opinion

March 31, 2026 591 Views 0 comment Print

The ITAT held that reopening was invalid as it was based on the same material already examined during the original assessment. It ruled that reassessment cannot be used to review a concluded issue.

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