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ITAT Pune

Section 69C Addition Restricted to Estimated Profit of Small Trader

January 9, 2026 717 Views 1 comment Print

The issue was whether total purchases could be treated as unexplained expenditure under section 69C. The Tribunal held that only the profit element is taxable in a small retail trading business.

Section 14A Disallowance Recomputed After Mutual Fund Exclusion

January 9, 2026 306 Views 0 comment Print

The assessee challenged a large section 14A disallowance on procedural and factual grounds. The Tribunal upheld satisfaction but ordered recomputation after excluding mutual fund investments.

Delay in Form 10AB Filing Excused Due to Late Grant of Prior Approval

January 9, 2026 597 Views 0 comment Print

Holding that there was no real delay, the Tribunal directed grant of section 80G approval. The decision stresses practical and reasonable interpretation of filing timelines.

Addition Set Aside for Lack of Cross-Examination Opportunity

January 9, 2026 348 Views 0 comment Print

An addition based on a third-party statement was challenged for denial of cross-examination. The Tribunal held that natural justice must be followed and directed a fresh hearing.

Reassessment Quashed for Wrong Approval Under Section 151

January 9, 2026 663 Views 0 comment Print

The issue was whether reassessment beyond three years was valid without approval from the correct authority. ITAT held the notice void as sanction was taken from the wrong officer, reaffirming strict compliance with Section 151.

Section 143(1) Adjustment Cannot Deny 115BAB Concessional Rate

January 9, 2026 834 Views 0 comment Print

Denial of the 15% rate through summary processing was held invalid. Eligibility under section 115BAB requires examination and hearing, not mechanical CPC adjustments.

ITAT Pune Deletes Section 234E Late Fee for Pre-1 June 2015 TDS Return Processing

January 9, 2026 546 Views 0 comment Print

The case dealt with a TDS return processed in March 2015 where late fee was levied. The Tribunal held such levy to be without jurisdiction under the law then in force.

Section 69 Addition Quashed Because Housing Loan Explained Source

January 9, 2026 402 Views 0 comment Print

The issue was whether cash and cheque payments could be taxed as unexplained investment in AY 2013–14. The Tribunal held that the major payments pertained to FY 2010–11 and could not be assessed in a later year.

Delay in Filing Condoned for Old Trust, Registration Matter Restored

January 9, 2026 429 Views 0 comment Print

Recognising the non-commercial nature of a long-standing charitable trust, the Tribunal condoned the delay. The registration application was sent back for reconsideration on merits.

Section 270A Penalty Case Remanded After Delay Condoned

January 9, 2026 384 Views 0 comment Print

Where the CIT(A) rejected the appeal only on limitation, the Tribunal intervened. It directed fresh adjudication of the penalty after condoning the 380-day delay.

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