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Addition U/s 69 for alleged on-money deleted – No corroborative evidence denial of cross-examination violates natural justice – ITAT Mumbai

Income Tax : The Tribunal held that additions under Section 69 cannot be sustained when based solely on third-party statements and unverified e...

February 14, 2026 9 Views 0 comment Print

U/s 69A Addition Partly Sustained – Estimated Relief Granted Considering Household Savings

Income Tax : ITAT held that a portion of cash paid could reasonably be sourced from accumulated withdrawals from joint bank accounts. The remai...

February 13, 2026 102 Views 0 comment Print

U/s 153C Assessment Quashed – Defective Satisfaction Note & Invalid Jurisdiction

Income Tax : The Tribunal held that assumption of jurisdiction under Section 153C was invalid due to a defective and consolidated satisfaction ...

February 13, 2026 84 Views 0 comment Print

Reassessment Quashed – No Addition on Original Reason for Reopening

Income Tax : The Tribunal held that reassessment proceedings fail when the Assessing Officer abandons the issue forming the basis of reopening....

February 13, 2026 162 Views 0 comment Print

Deduction U/s 54F Allowed – Deposit in CGAS Not Mandatory if Investment Made Within Extended Time

Income Tax : The Tribunal observed that ₹99.10 lakh allegedly added as unexplained credits may represent earlier year balances. The matter wa...

February 13, 2026 240 Views 0 comment Print


Penalty Collapses Automatically Once Quantum Addition Is Deleted

December 27, 2025 402 Views 0 comment Print

The tribunal ruled that a penalty under section 271(1)(c) cannot stand when the quantum addition forming its basis is deleted. The key takeaway is that penalty proceedings automatically fail without a surviving assessment addition.

Mechanical Dismissal Fails as CIT(A) Skips Speaking Order

December 26, 2025 435 Views 0 comment Print

ITAT held that dismissing a ground without reasons violates appellate duty. The 43B disallowance was remanded for fresh, reasoned adjudication.

Additions Can’t Be Based on Suspicion, ITAT Deletes 2.5% Profit

December 26, 2025 255 Views 0 comment Print

The Tribunal held that profit estimation cannot rest on conjectures or lump-sum allegations. In absence of identified bogus purchases or factual basis, the entire addition was deleted.

Purchase Return Dispute Not Misreporting, Penalty Quashed

December 26, 2025 231 Views 0 comment Print

Delhi ITAT held that a purchase-return mismatch does not constitute misreporting under section 270A(9). Immunity under section 270AA was granted, quashing the ₹10.69 lakh penalty.

Comparable Excluded Due to Functional Dissimilarity in Software Development Transfer Pricing

December 25, 2025 447 Views 0 comment Print

Tribunal held that a company engaged in diversified IT consultancy and transformation services cannot be compared with a routine software development service provider

Income Tax Assessment Upheld Because Amalgamation Was Not Informed to Tax Officer

December 25, 2025 249 Views 0 comment Print

The Tribunal ruled that failure to formally intimate amalgamation sustained the assessment, applying Mahagun Realtors, while striking down mechanical expense disallowances.

Section 271D Penalty Quashed Because Transaction Was Accepted as Genuine

December 25, 2025 339 Views 0 comment Print

The Tribunal held that once cash received was accepted in assessment without any addition, penalty for alleged violation of Section 269SS could not be sustained.

Capital Gains Taxable Despite Gram Panchayat Certificate When Land Is Within 8 km of Municipality

December 25, 2025 438 Views 0 comment Print

The Tribunal examined whether agricultural land qualified as a non-capital asset and upheld taxation after finding it within the prescribed municipal distance. The ruling reiterates that physical verification and reliable evidence prevail over unsupported certificates.

Section 115BBE Not Applicable to Business Receipts; Only Profit on Cash Deposits Taxable

December 25, 2025 336 Views 0 comment Print

The Tribunal held that cash deposits representing trading receipts cannot be taxed in full as unexplained income. Only the estimated profit portion was directed to be assessed.

Excess Stock from Survey Taxable as Business Income, Section 115BBE Inapplicable

December 25, 2025 696 Views 0 comment Print

The Tribunal held that excess stock found during survey, when arising from regular business activity and disclosed in accounts, cannot be taxed as unexplained investment under Section 69B.

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