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Section 250

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Bogus Purchase Addition Limited to Profit Element Due to Accepted Sales: ITAT Mumbai

Income Tax : ITAT held that where sales are not disputed, entire purchases cannot be disallowed. Only 15% profit element was taxed, reinforcing...

April 18, 2026 327 Views 0 comment Print

Reopening on Change of Opinion Invalid: ITAT Quashes Entire Assessment

Income Tax : The Tribunal quashed reassessment proceedings as they were based on a mere change of opinion without any fresh tangible material. ...

April 18, 2026 66 Views 0 comment Print

Mass Relief on 234E Fees: ITAT Deletes Levy for Pre-01.06.2015 Period

Income Tax : The issue involved levy of late fees on TDS returns processed before statutory amendment. The Tribunal held that absence of enabli...

April 18, 2026 69 Views 0 comment Print

DVO Valuation Without Notice Invalid: Matter Remanded for Fresh Determination

Income Tax : The Tribunal held that valuation without giving the assessee an opportunity to object violates natural justice. It remanded the ma...

April 18, 2026 39 Views 0 comment Print

Section 68 Additions Fail: Documentary Evidence Cannot Be Ignored Without Enquiry

Income Tax : The Tribunal condoned delay due to reasonable cause and addressed valuation mismatch. It remanded the issue for DVO-based reassess...

April 18, 2026 147 Views 0 comment Print


ITAT Allows Software Expenses as Revenue Because Licences Were Short-Term and Non-Exclusive

March 1, 2026 840 Views 0 comment Print

Tribunal held that application software licences with limited duration and no ownership rights are revenue expenditure. It deleted the disallowance and ruled that remand by the Commissioner (Appeals) was unjustified.

No Unexplained Income When Farmer Loan Repayments in SBN Fully Recorded in Books: ITAT Ahmedabad

February 28, 2026 321 Views 0 comment Print

The Tribunal held that mere acceptance of demonetized currency during the demonetization period cannot justify addition under Section 68 when identity, genuineness, and source are established. Revenue’s appeal was dismissed.

ITAT Deletes ₹50 Lakh On-Money Addition; Section 54F Issue Remanded to check Commercial Use

February 27, 2026 288 Views 0 comment Print

Section 54F Deduction Remanded as Tenants’ Affidavits Suggest Commercial Use of Properties,  No Addition Without Corroborative Evidence: ITAT Deletes ₹50 Lakh On-Money Addition in Property Deal and Presumption Under Section 132(4A) Cannot Be Applied Against Assessee When Documents Seized from Third Party

Unsecured Loan Addition U/s 68 Deleted; Banking Repayment & Identity Proved, No Need to Prove Source of Source – ITAT Ahmedabad

February 25, 2026 435 Views 0 comment Print

The Tribunal deleted the ₹60 lakh addition under Section 68 after noting that the loan was received and repaid through banking channels and the lenders identity was established.

Audit fees allowed as expense as commencement of business proved and expense incurred wholly for business

February 25, 2026 303 Views 0 comment Print

ITAT Panaji held that disallowance of audit fees is not justifiable since commencement of business operation is recognised under the Companies Act and expenditure was incurred wholly and exclusively for business. Accordingly, appeal allowed to that extent.

Section 69 Property Addition Deleted – Agreement vs Sale Deed Difference Not Sufficient Evidence: ITAT Ahmedabad

February 24, 2026 324 Views 0 comment Print

The Tribunal upheld deletion of addition made on alleged unexplained investment in property. It held that difference between initial agreement value and final sale deed, without evidence of extra payment, cannot justify addition under Section 69.

₹1 Cr Penny Stock Addition u/s 69A Deleted – Reopening Based on Borrowed Satisfaction & No Assessee-Specific Evidence: ITAT Ahmedabad

February 24, 2026 333 Views 0 comment Print

The Tribunal ruled that invoking clause (i) instead of clauses (iii)/(iv) of Explanation 2 was legally incorrect where material belonged to another person. The reassessment proceedings were quashed for non-compliance with statutory procedure.

Section 50C Inapplicable Where Property Rights Relinquished Earlier by Registered Agreement

February 23, 2026 606 Views 0 comment Print

The Tribunal held that transfer took place in 2000 upon execution of a registered development agreement and receipt of full consideration, not in 2008 when the sale deed was executed.

ITAT Indore Sets Aside FTC Disallowance as Form 67 Filed With Section 139(4) Return

February 23, 2026 315 Views 0 comment Print

The Tribunal found that denial of foreign tax credit during return processing was improper where Form 67 and the return were filed together. The Assessing Officer was directed to verify and allow credit.

Section 68 Addition Deleted as PAN, ITR and Confirmations Proved Loan Creditworthiness

February 23, 2026 2229 Views 0 comment Print

Tribunal upheld deletion of unsecured loan addition after finding identity, creditworthiness, and genuineness established through PAN, ITRs, bank statements, and TDS records.

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