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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 333 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 72 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


Demonetisation Cash Deposit Fails ‘Old Withdrawal’ Explanation

December 30, 2025 294 Views 0 comment Print

The issue was whether year-old cash withdrawals could explain demonetisation-era deposits. ITAT held that absence of a direct nexus and contrary bank entries justified addition under section 69A.

Reassessment dropped as tax paid on consolidated profit and hence no escapement of income

December 30, 2025 573 Views 0 comment Print

ITAT Rajkot held that there is no escapement of income or loss of revenue since tax paid on the basis of consolidated profit of both the partnership firm and hence reassessment proceedings are not sustainable. Accordingly, appeal of revenue is dismissed.

CIT(A) Can Call for Evidence Directly – No Rule 46A Violation

December 30, 2025 318 Views 0 comment Print

The Tribunal upheld deletion of unsecured loan additions where the appellate authority independently examined lender details. The key takeaway is that CIT(A) can call for and rely on necessary evidence to decide appeals on merits.

Section 147 Reopening Can’t Be Based Only on Cash Deposit Alerts

December 30, 2025 378 Views 0 comment Print

The Tribunal quashed reassessment where the Assessing Officer invoked section 147 without examining books of account or correlating bank deposits with returned income.

NFAC Can’t Dismiss Appeal by Forcing Separate 143(1) Challenge

December 30, 2025 441 Views 0 comment Print

The Tribunal held that once a regular assessment under section 143(3) is completed, earlier CPC adjustments under section 143(1) merge with it and lose independent existence.

Dumb Electronic Documents Cannot Create Taxable Investment

December 30, 2025 216 Views 0 comment Print

Mumbai ITAT upholds deletion of ₹70 lakh under Section 69, ruling that uncorroborated WhatsApp scribbles from a third party cannot establish unexplained cash income.

Redevelopment Gains Are LTCG If Rights Crystallised Earlier

December 30, 2025 411 Views 0 comment Print

ITAT Mumbai ruled that for redeveloped flats, the allotment date marks acquisition, confirming long-term capital gains eligibility under section 54, despite later possession.

Old Cash Withdrawal Claim Rejected for Demonetisation Deposits

December 29, 2025 531 Views 0 comment Print

The Tribunal upheld addition of demonetisation cash deposits after rejecting the claim that funds came from old cash withdrawals. Mere assertion of past withdrawals, without evidence of cash retention, was held insufficient.

Mechanical Appellate Order Quashed for Ignoring Rule 46A

December 29, 2025 465 Views 0 comment Print

The Tribunal found the appellate order mechanical where Rule 46A evidence was filed but not examined. The matter was sent back for fresh adjudication after proper verification.

Interim Compensation Not Taxable Until Final Court Settlement

December 29, 2025 429 Views 0 comment Print

The Tribunal held that compensation received under interim court orders is contingent and does not accrue as income. Taxability arises only in the year when litigation is finally settled and the amount crystallises.

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