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Income Tax : A surge in Section 143(2) notices was triggered by the June 2025 limitation deadline. This explains why cases were picked and how ...
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Income Tax : Tribunal observed that the Assessing Officer failed to establish any mismatch in stock, sales, or accounting records before making...
Income Tax : ITAT Hyderabad held that constituent members of a JV or Consortium can claim deduction under Section 80IA(4) when they actually ex...
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Income Tax : ITAT Rajkot held that cash deposits made during demonetization were fully supported by audited books of account, cash books, and b...
Income Tax : The Hyderabad ITAT held that purchases cannot be treated as bogus merely because the supplier failed to respond to a notice under ...
Income Tax : Instruction No.1/2015 Clarification regarding applicability of section 143(1D) of the Income-tax Act, 1961- Vide Finance Act, 2012...
The Tribunal upheld the rejection of unreliable books but ruled that the AO could not estimate net profit at 12% without justification, vacating ₹65.08 lakh addition.
ITAT restored Rs. 20 Cr in unsecured loans, interest, and squared-up loans for fresh verification, noting CIT(A) erred by deleting additions at the stroke of a pen. Large new loans and substantial repayments required independent checks on purpose and creditworthiness. The ruling reinforces that appellate deletion without inquiry violates Rule 46A and legal principles under sections 68 and 69.
The issue involved a common sanction letter covering multiple assessees and years, issued on the same day the AO sought approval. ITAT found this composite approval inconsistent with judicial mandates requiring individualized scrutiny. As a result, the assessment was declared void ab initio, making all additions infructuous.
The Tribunal held that the AO’s rejection of books under Section 145(3) was unsustainable as no specific defects were identified. The ruling confirms that estimation of income cannot be based on assumptions when records are supported by documentation.
The Tribunal ruled that the AO erred in applying a 15% illiquidity discount on shares valued by the NAV method. SEBI MF guidelines and DCF-based precedents were deemed irrelevant. The assessee’s valuation was confirmed, and the Rs. 8.70 crore addition was nullified.
The Tribunal held that passing assessment orders after the statutory one-month period prescribed under Section 144C(13) is invalid. The assessee’s appeals were allowed, and both orders were set aside.
The Tribunal held that additions must be supported by actual evidence, not mere surmise from third-party statements. The assessee’s invoices and valuer reports disproved alleged cash payments, leading to complete deletion of additions.
The Tribunal observed that identity, creditworthiness, and genuineness were proven through confirmations, returns, and banking trails, and the AO failed to conduct enquiries under Sections 133(6) or 131. It also held that the ₹6.45 lakh loan difference belonged to past years, making the entire ₹22.45 lakh addition unsustainable.
Gujarat High Court held that reopening of assessment under section 148 of the Income Tax Act is mere change of opinion since there is no failure on part of assessee as to full and true disclosure. Accordingly, reassessment is liable to be quashed and set aside.
The Tribunal ruled that CSR expenses donated to recognized charitable institutions satisfy the conditions of Section 80G. It emphasized that statutory CSR obligations do not interfere with 80G eligibility and directed allowance of the deduction.
