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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 315 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 60 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 66 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


Section 14A Interest Disallowance Deleted Due to Availability of Interest-Free Funds

January 11, 2026 264 Views 0 comment Print

The Tribunal held that when interest-free funds exceed exempt-income investments, no interest disallowance under Section 14A can be made. The ruling reinforces the presumption laid down by the Supreme Court.

Assessment Framed on Deceased Assessee Is Void Ab Initio

January 10, 2026 660 Views 0 comment Print

The issue was whether an assessment can continue after the assessee’s death. The Tribunal held such an order void ab initio when the legal heir is not substituted.

Unexplained Jewellery Addition Scaled Down on Human Probability

January 10, 2026 552 Views 0 comment Print

The Tribunal applied common sense to accept that some jewellery belonged to visiting relatives. It granted partial deletion, stressing that complete relief requires corroborative evidence.

Section 143(1) Adjustment Cannot Deny 115BAB Concessional Rate

January 9, 2026 834 Views 0 comment Print

Denial of the 15% rate through summary processing was held invalid. Eligibility under section 115BAB requires examination and hearing, not mechanical CPC adjustments.

No Section 68 Addition When Capital Introduction Pertains to Another Year

January 9, 2026 402 Views 0 comment Print

The Tribunal upheld deletion of a ₹2.27 crore addition after finding that the capital deposit did not pertain to the assessment year in question. Without a year-wise nexus, section 68 could not be invoked.

Section 40A(3) Disallowance Set Aside in Invalid Reassessment

January 9, 2026 255 Views 0 comment Print

The case examined whether reassessment after four years was valid when the issues were already examined in scrutiny. The Tribunal held the reopening invalid as a mere change of opinion and quashed the reassessment.

Section 40 Disallowance Fails for Overseas Commission Payments

January 9, 2026 390 Views 0 comment Print

The case clarifies that commission paid to foreign agents for export facilitation abroad cannot be disallowed for non-deduction of tax. Absence of income accrual in India was decisive.

ITAT Mumbai deleted Bogus LTCG additions for Lack of Direct Evidence

January 8, 2026 564 Views 0 comment Print

The Tribunal held that long-term capital gains from listed share sales could not be treated as bogus merely due to high profits. In the absence of contrary evidence, additions under Sections 68 and 69C were deleted.

Artificial profit/loss arising from client code modification requires transaction-wise reconciliation-Matter restored

January 8, 2026 363 Views 0 comment Print

ITAT Mumbai held that artificial profits or losses arising from Client Code Modification in share transactions carried out in F&O segment requires transaction-wise reconciliation. Accordingly, matter restore to the file of AO.

Section 68 Addition for mere Non-Compliance to Summons: ITAT Kolkata

January 8, 2026 315 Views 0 comment Print

The AO accepted documents but still made an addition without pointing out defects. The Tribunal ruled that section 68 requires adverse findings, not assumptions.

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