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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


No disallowance under rule 8D(2)(ii) as interest-free own funds exceeds investment

February 6, 2026 390 Views 0 comment Print

ITAT Mumbai held that disallowance of interest expenditure under Rule 8D(2)(ii) of the Income Tax Rules is not sustainable since the assessee’s own interest-free funds were substantially higher than the investment. Accordingly, appeal of revenue dismissed and order of CIT(A) upheld.

Vivad-Se-Vishwas Didn’t Mature — Appeal Can’t Die by Assumption

February 6, 2026 894 Views 0 comment Print

ITAT Chennai held that merely opting for Vivad-Se-Vishwas does not end an appeal unless settlement is completed; dismissal by assumption was invalid and appeal was restored for merits adjudication.

Borrowed Satisfaction from Insight Portal Invalid; Re-opening Section 68 Addition Quashed

February 6, 2026 477 Views 0 comment Print

The issue was whether reopening based only on portal information is valid. The Tribunal held that absence of independent inquiry and tangible material vitiates reassessment and nullifies the addition.

143(1) Adjustment Without Prior Intimation Invalid; CPC Action Quashed

February 6, 2026 570 Views 0 comment Print

The tribunal held that any adjustment while processing a return under Section 143(1) requires prior intimation to the assessee. Disallowance made without issuing such notice is invalid in law.

Commission Agent Theory Accepted; Entire Bank Credits Not Taxable U/s 68

February 6, 2026 480 Views 0 comment Print

The tribunal held that large cash deposits in bank accounts cannot be taxed as unexplained income when the assessee proves he acted only as a commission agent. Only commission income, and not gross deposits, is taxable in such cases.

Section 249(4)(b) Dismissal Reversed; One Opportunity to Explain Advance-Tax Liability

February 6, 2026 222 Views 0 comment Print

The issue was dismissal of appeals for non-payment of admitted tax without hearing on merits. The Tribunal restored the appeals, holding that the assessee deserved an opportunity to explain advance tax liability.

Third-Party DD Payment Explains Investment; U/s 69 Addition Deleted

February 6, 2026 219 Views 0 comment Print

The ITAT ruled that once the assessee establishes the source of investment, addition for unexplained investment cannot survive. Direct payment by a financier through demand draft explained the transaction.

Scrutiny Valid Despite Section 12A Rejection; Merits Restored Pending Registration Outcome

February 6, 2026 237 Views 0 comment Print

The case examined taxation of a charitable entity when registration under Section 12A was unsettled. While scrutiny selection was upheld, the assessment was remanded to await the outcome of registration proceedings.

145(3) Upheld but 1% NP Excessive; Beer Trader’s Margin Rationalised to 0.50%

February 5, 2026 285 Views 0 comment Print

Unexplained cash deposits and rent discrepancies led to rejection of books under section 145(3). However, the Tribunal held that estimating profits at 1% was excessive and moderated it to 0.50%.

Interest on Unutilised Government Grants Exempt: ITAT Ahmedabad

February 5, 2026 300 Views 0 comment Print

The Tribunal ruled that interest earned on Government grants parked under official directions cannot be divorced from the original grant. Denial of exemption was found to defeat the purpose of section 10(23C)(iiiab), leading to relief for the assessee.

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