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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 303 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 54 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 138 Views 0 comment Print


Foreign Tax Credit Allowed as Form 67 Delay Is Procedural: ITAT Mumbai

January 8, 2026 501 Views 0 comment Print

The Tribunal examined whether delayed filing of Form 67 can defeat a valid FTC claim. It ruled that Rule 128(9) is directory and FTC cannot be denied when substantive conditions are met.

Section 68 Addition Quashed for Exceeding Limited Scrutiny Scope: ITAT Mumbai

January 8, 2026 510 Views 0 comment Print

The issue was whether the Assessing Officer could invoke section 68 in a limited scrutiny case focused on share premium under section 56(2)(viib). The Tribunal held that, without mandatory approval to expand scrutiny, the addition was legally unsustainable.

Gold Jewellery Seized u/s 132A Held Explained – Addition u/s 69 r.w.s. 115BBE Deleted

January 8, 2026 288 Views 0 comment Print

The tribunal examined whether gold jewellery seized during police interception could be taxed as unexplained solely based on a statement recorded under enquiry. It held that additions fail where later evidence shows the assessment relied on weak corroboration and inconsistent reasoning.

TDS credit reflected in 26AS cannot be denied for procedural lapse: ITAT Mumbai

January 7, 2026 837 Views 0 comment Print

ITAT Mumbai held that TDS credit duly reflected in Form 26AS cannot be denied just because of some procedural lapse. Accordingly, order is set aside and the present appeal is allowed.

On-Money Gross Receipts Not Taxable, Only Profit Can Be Assessed

January 6, 2026 3429 Views 0 comment Print

The Revenue sought to tax total on-money collected under section 69A. The ITAT ruled that on-money forms part of business receipts and must be assessed on a profit basis. The key takeaway is that taxation cannot ignore unaccounted expenses linked to such receipts.

Agreed Addition Not Conclusive Where Law Grants Exemption

January 6, 2026 285 Views 0 comment Print

Capital gains arose from land compulsorily acquired by a government authority. ITAT directed the AO to re-examine eligibility for exemption under Section 10(37).

Revenue Appeal Infructuous After Section 263 Order Set Aside

January 6, 2026 459 Views 0 comment Print

ITAT Ahmedabad held that if a Section 263 revision order is quashed, any consequential assessment and appeals based on it are rendered inoperative. Key takeaway: assessments cannot stand on invalid foundations.

Notice Issued for Incorrect Year Renders Reassessment Void

January 6, 2026 309 Views 0 comment Print

The reassessment was initiated for AY 2013-14 using reasons recorded for AY 2012-13. ITAT held that reopening for the wrong year is void, causing the entire Section 147 assessment to collapse.

Books Not Proper, Estimated Income Still Penalised by ITAT

January 6, 2026 366 Views 0 comment Print

ITAT Jaipur confirmed that Section 270A(6)(b) exclusion is inapplicable when accounts are incorrect or incomplete. Key takeaway: defective records make estimated disallowances liable to penalty.

Husband-to-Wife Property Gift Exempt, ₹1.78 Cr Addition Deleted

January 6, 2026 480 Views 0 comment Print

The AO questioned genuineness and love and affection behind the gift. The ITAT held that once relationship and capacity are proved through documents, no addition can survive.

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