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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


ITAT Mumbai: On-Money Addition Based on Third-Party Evidence Excel Sheets Deleted

April 13, 2026 459 Views 0 comment Print

The Tribunal held that additions based solely on third-party statements and Excel sheets are unsustainable without independent evidence. It emphasized that denial of cross-examination violates natural justice and invalidates the addition.

ITAT Mumbai: No Section 56(2)(x) Addition if Difference Within 10%-Tolerance Limit Held Retrospective

April 13, 2026 165 Views 0 comment Print

The case examined whether minor valuation differences can trigger taxation under Section 56(2)(x). ITAT held that differences within 10% fall within permissible tolerance. The ruling protects genuine transactions from arbitrary additions.

ITAT Mumbai Quashes Reopening: Approval by Wrong Authority u/s 151 Makes Entire Reassessment Void

April 13, 2026 162 Views 0 comment Print

The case addresses whether reassessment is valid when approval is granted by the wrong authority. ITAT held that sanction under Section 151 is jurisdictional and must be from the correct authority. The entire reassessment was quashed for non-compliance.

ITAT Mumbai: No Ad-hoc Disallowance Without Rejecting Books; Section 40(a)(ia) Relief If TDS Paid Before Return Due Date

April 13, 2026 207 Views 0 comment Print

The case examines whether estimated expense disallowances can be made without rejecting books of account. ITAT held such additions invalid, emphasizing that Section 145(3) rejection is a prerequisite. The ruling protects taxpayers from arbitrary disallowances.

ITAT Mumbai: Section 11(5) Shortfall from Earlier Years Cannot Be Taxed; Only Current Year Violation Taxable

April 13, 2026 336 Views 0 comment Print

ITAT Mumbai rules that Section 11(5) investment shortfall of earlier years cannot be taxed in the current year, holding amendment prospective. Only current year violation is taxable, restricting addition to ₹5 lakh and deleting ₹1.34 crore.

ITAT Mumbai: Reopening Invalid on Change of Opinion-No Fresh Material, Assessment Quashed

April 13, 2026 129 Views 0 comment Print

ITAT held reassessment invalid as it was based on already examined facts without fresh material. The ruling reinforces that reopening on mere change of opinion is not permissible.

ITAT Mumbai: Interest from Co-Operative Banks Eligible U/s 80P(2)(d)-Consistency Principle Applied

April 13, 2026 108 Views 0 comment Print

The Tribunal held that interest earned from deposits with co-operative banks is eligible for deduction under Section 80P(2)(d). It clarified that co-operative banks are treated as co-operative societies for this purpose.

ITAT Mumbai: Delay in Filing Form 67 Not Fatal-Foreign Tax Credit Cannot Be Denied on Technical Grounds

April 13, 2026 96 Views 0 comment Print

The Tribunal emphasized that procedural lapses should not defeat substantive tax relief. It held that Form 67 filed during rectification proceedings is valid compliance, allowing reconsideration of FTC claim.

ITAT Mumbai: BSNL VRS Compensation is Capital Receipt-Exempt u/s 10(10B); Delay Condoned

April 13, 2026 903 Views 0 comment Print

The Tribunal condoned a 1394-day delay, prioritizing substantial justice over procedural lapses. It ruled that BSNL VRS compensation qualifies as exempt retrenchment compensation under Section 10(10B), allowing full tax relief and refund.

Excess Stock cannot be treated as Treated as unexplained investment without Evidence of Unexplained Sources

April 13, 2026 297 Views 0 comment Print

The Tribunal held that the Assessing Officer went beyond revisionary directions by including additional issues. It ruled that such excess additions were invalid and liable to be deleted.

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