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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 345 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


Appeals Rejected Due to Unexplained Nine-Year Delay in Filing

December 29, 2025 285 Views 0 comment Print

The assessee sought relief citing internal lapses and adviser dependence. The Tribunal ruled that consistent audits and filings undermined claims of ignorance. Long delays require specific, convincing justification, which was absent.

No Rule 46A Breach When CIT(A) Calls Records Suo-Motu: ITAT

December 29, 2025 249 Views 0 comment Print

Demonetisation cash deposits cannot be taxed merely on suspicion when supported by statutory VAT/Excise records, sales growth, and business expansion. Rule 46A(4) empowers CIT(A) to call for such evidence without triggering procedural violations.

Property Sale Deductions Get Second Chance: Capital Gains Recomputed

December 29, 2025 225 Views 0 comment Print

Rejecting a summary denial of deductions, the Tribunal restored the issue to the AO to verify whether mortgage repayments and other costs were wholly connected with the transfer. Taxpayers were directed to cooperate and file complete evidence.

Tribunal reversing order of CIT(A) without demonstrating any perversity is not justifiable

December 29, 2025 447 Views 0 comment Print

Patna High Court held that ITAT was not justified in reversing the order of CIT(A) without demonstrating any perversity, misreading of evidence, or application of an incorrect legal standard by the appellate authority. Accordingly, deletion of addition u/s. 68 by CIT(A) justified and writ allowed.

Kolkata ITAT Quashes Time-Barred Reopening for AY 2015-16

December 28, 2025 468 Views 0 comment Print

The ITAT held that reassessment initiated in July 2022 for AY 2015-16 was barred by limitation. The ruling confirms that expired cases cannot be revived under the post-2021 reassessment framework.

DGIT (Inv.) Inputs Alone Can’t Justify Reopening: ITAT

December 27, 2025 717 Views 0 comment Print

ITAT found the recorded reasons vague and non-specific, failing to even identify the nature of alleged escapement. Such mechanical reasons render the notice under section 148 void ab initio.

Wrong ITR Column Can’t Deny Trust Exemption: ITAT Kolkata

December 27, 2025 780 Views 0 comment Print

The Tribunal condoned an extraordinary 2315-day delay, noting that the disallowance arose from a return-filing error and not lack of application of income. The matter was restored for fresh adjudication on merits.

No Incriminating Material, No Addition in Section 153A Assessments

December 27, 2025 603 Views 0 comment Print

Whether additions under sections 68 and 69C can be made without seized material. In search cases, completed assessments cannot be disturbed unless incriminating material is found during the search.

GP Rate Refined to 11% in Search-Based Bogus Purchase Case

December 27, 2025 684 Views 0 comment Print

The issue was whether entire alleged bogus purchases should be added as income after a search assessment. The Tribunal held that where consumption and records are not disputed, only the profit element can be taxed, not the full purchase value.

No Trade, No Income – Broker’s PAN Error Collapses Addition

December 27, 2025 249 Views 0 comment Print

The case examined whether exchange data alone could justify taxing alleged commodity profits. The Tribunal ruled that once the broker admits wrong PAN mapping and identifies the real trader, the addition cannot survive.

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