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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


Denial of depreciation to trust not justified as genuineness of building construction expense proved

February 6, 2026 123 Views 0 comment Print

ITAT Bangalore held that once the genuineness of the building construction expenditure is proved, the consequential claim of depreciation on such genuine assets cannot be denied to trust since depreciation was claimed only on actual assets used for charitable purpose.

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

February 6, 2026 219 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 552 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 246 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 246 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 171 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 63 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 75 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 78 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 132 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%.

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