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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 174 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 78 Views 0 comment Print


Addition u/s 56(2)(viib) Invalid as AO Cannot Reject DCF Valuation Without Defects: ITAT Delhi

April 15, 2026 405 Views 0 comment Print

ITAT held that once an assessee adopts a prescribed valuation method under Rule 11UA, the AO cannot change or substitute it. The ruling reinforces taxpayer autonomy in selecting valuation approaches.

Bank Deposits Treated as Business Turnover – ITAT Reduces Profit Rate from 10% to 2%

April 15, 2026 4977 Views 0 comment Print

The Tribunal ruled that bank deposits cannot be treated as unexplained income when linked to regular business activity. It upheld that consistent past records supported the assessee’s claim of business receipts.

ITAT Hyderabad: Foreign Tax Relief Must Be Deducted While Computing Interest U/s 234A/B/C

April 15, 2026 171 Views 0 comment Print

The issue was incorrect computation of interest without reducing foreign tax relief. ITAT held that relief under sections 90/90A must be deducted before calculating interest under sections 234A, 234B, and 234C.

ESOP Discount Allowed as Revenue Expense: ITAT rejects Notional Loss Claim

April 14, 2026 171 Views 0 comment Print

The Tribunal upheld deduction of ESOP expenses, relying on earlier decisions in the same case. It ruled that no change in facts justified a different view.

ITAT Rajkot: Hybrid Seed Company’s Income Held as Agricultural

April 14, 2026 78 Views 0 comment Print

The issue was whether income from hybrid seed production on leased land qualifies as agricultural income. The Tribunal held that ownership is not necessary if the assessee exercises control, bears risk, and performs agricultural operations.

ITAT Rajkot: Mechanical Approval Invalid – Reopening U/s 148 Quashed

April 14, 2026 120 Views 0 comment Print

The issue was validity of reopening based on approval lacking proper application of mind. The Tribunal held such mechanical approval invalid, rendering the reassessment void.

ITAT Mumbai: Section 68 Addition Deleted – Mere Suspicion & Third-Party Info Not Enough

April 14, 2026 102 Views 0 comment Print

The issue was whether addition can be made based on third-party investigation findings. The Tribunal held that without direct incriminating evidence, such addition is unsustainable, emphasizing the need for nexus.

Abandoned Business Project Expenses Allowed as Deduction Due to Business Purpose

April 14, 2026 312 Views 0 comment Print

Expenses incurred for a proposed business project later abandoned were allowed as revenue expenditure. The Tribunal held that such costs remain deductible if incurred for business purposes.

Additional Evidence Rejected Due to Violation of Income Tax Rule 46A Procedures

April 14, 2026 426 Views 0 comment Print

The Tribunal held that the CIT(A) improperly admitted additional evidence without satisfying Rule 46A conditions or recording reasons. It emphasized that procedural compliance is mandatory and failure to follow it invalidates the relief granted.*

ITAT Mumbai: No Penalty U/s 271(1)(c) on Estimated Bogus Purchase Additions

April 13, 2026 315 Views 0 comment Print

The Tribunal held that penalty under Section 271(1)(c) cannot be imposed when additions are made on an estimated basis. It upheld deletion of penalty, emphasizing absence of concrete evidence of concealment.

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