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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 156 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 36 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 60 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 36 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 63 Views 0 comment Print


Full Exemption of Leave Encashment Allowed – Government Service Character Prevails Over PSU Status

April 18, 2026 126 Views 0 comment Print

The Tribunal held that leave encashment relating to government service remains fully exempt under Section 10(10AA). It ruled that later absorption into a PSU does not change the nature of the benefit.

Reassessment Quashed as Wrong Provision Invoked Instead of Section 153C: ITAT Jaipur

April 17, 2026 267 Views 0 comment Print

The Tribunal held that reopening under Section 147 was invalid where it was based on third-party search material. It ruled that Section 153C was the correct legal route, leading to deletion of additions.

Section 271(1)(c) Penalty Deleted Due to Consistency with Earlier Year Ruling: ITAT Dehradun

April 16, 2026 204 Views 0 comment Print

The Tribunal held that penalty under section 271(1)(c) cannot be sustained when identical facts in earlier years led to deletion. Applying the principle of consistency, the penalty was deleted.

Duty Drawback Taxable Only on Receipt – ITAT Deletes Addition & U/s 270A Penalty

April 16, 2026 126 Views 0 comment Print

The tribunal examined whether duty drawback should be taxed on accrual or actual receipt. It held that as per law, duty drawback is taxable only in the year of receipt, and additions based on accrual were unsustainable.

Disallowance of Interest Unsustainable Without Final Decision on Loan Validity: ITAT Mumbai

April 16, 2026 243 Views 0 comment Print

The Tribunal held that disallowance of interest cannot be finalized when the validity of underlying loans is still under appeal. It remanded the matter for reconsideration after the earlier year’s decision.

Section 14A Disallowance Restricted to Exempt-Income Investments; ESOP Expense Allowed

April 16, 2026 189 Views 0 comment Print

Tribunal rules that Section 14A disallowance must be limited to investments yielding exempt income and orders recomputation under Rule 8D. It also allows ESOP expenses as a valid business deduction under Section 37(1), treating them as an ascertained liability and not a notional or capital expense.

No FTS on Project-Specific Design Services; ‘Make Available’ Test Not Met, No Disallowance u/s 40(a)(i)

April 16, 2026 117 Views 0 comment Print

The Tribunal held that consultancy payments for architectural services were not FTS since no technical knowledge was made available. Disallowance under Section 40(a)(i) was deleted.

ITAT Disallows Double Exemption & Unutilised Accumulation u/s 11; Revenue Appeal Allowed

April 16, 2026 219 Views 0 comment Print

The issue was whether utilisation of earlier accumulated income qualifies for fresh exemption. The Tribunal held it amounts to double deduction as exemption was already claimed earlier.

Bogus Purchases addition Based on Investigation Reports Fails Where Evidence Exists: ITAT Delhi

April 15, 2026 258 Views 0 comment Print

The issue was whether purchases could be treated as bogus based on investigation reports. ITAT held that when documentary evidence and asset existence are proven, additions cannot be sustained.

Section 69C Addition Deleted as Purchases Supported by Documentary Evidence

April 15, 2026 252 Views 0 comment Print

The Tribunal held that purchases cannot be treated as bogus when supported by invoices, bank payments, and GST records. It ruled that absence of adverse evidence makes such additions unsustainable.

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