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ITAT Pune

Additions Based on mere Third-Party Loose Papers Quashed by ITAT Pune

January 13, 2026 852 Views 0 comment Print

The Tribunal set aside an addition made only on documents seized from a builder during search proceedings. The ruling underscores that independent evidence against the assessee is mandatory.

Non-examination of issue of depreciation claimed on goodwill justifies revision u/s. 263

January 12, 2026 351 Views 0 comment Print

ITAT Pune held that non-examination of issue of depreciation claimed on goodwill justifies invocation of revisionary proceeding under section 263 of the Income Tax Act. Accordingly, order sustained and appeal of assessee dismissed.

Deduction Allowed Since Form 10CCB Audit Report Filed Before Processing of Return

January 12, 2026 738 Views 0 comment Print

The Tribunal held that a deduction cannot be disallowed merely due to delayed filing of Form 10CCB when it was available before processing. Procedural delay does not defeat a valid deduction claim.

Section 14A Interest Disallowance Deleted Due to Availability of Interest-Free Funds

January 11, 2026 333 Views 0 comment Print

The Tribunal held that when interest-free funds exceed exempt-income investments, no interest disallowance under Section 14A can be made. The ruling reinforces the presumption laid down by the Supreme Court.

Substantive 80G Claim Revived Despite Inadvertent Filing Mistake

January 9, 2026 438 Views 0 comment Print

The issue was denial of regular 80G approval due to an inadvertent filing under an incorrect clause. The Tribunal held that a procedural mistake should not bar substantive adjudication.

Section 69C Addition Restricted to Estimated Profit of Small Trader

January 9, 2026 864 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 438 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 768 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 453 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 807 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.

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