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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 264 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 39 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 117 Views 0 comment Print


Mechanical Dismissal Fails as CIT(A) Skips Speaking Order

December 26, 2025 507 Views 0 comment Print

ITAT held that dismissing a ground without reasons violates appellate duty. The 43B disallowance was remanded for fresh, reasoned adjudication.

Additions Can’t Be Based on Suspicion, ITAT Deletes 2.5% Profit

December 26, 2025 348 Views 0 comment Print

The Tribunal held that profit estimation cannot rest on conjectures or lump-sum allegations. In absence of identified bogus purchases or factual basis, the entire addition was deleted.

Purchase Return Dispute Not Misreporting, Penalty Quashed

December 26, 2025 300 Views 0 comment Print

Delhi ITAT held that a purchase-return mismatch does not constitute misreporting under section 270A(9). Immunity under section 270AA was granted, quashing the ₹10.69 lakh penalty.

Comparable Excluded Due to Functional Dissimilarity in Software Development Transfer Pricing

December 25, 2025 690 Views 0 comment Print

Tribunal held that a company engaged in diversified IT consultancy and transformation services cannot be compared with a routine software development service provider

Income Tax Assessment Upheld Because Amalgamation Was Not Informed to Tax Officer

December 25, 2025 324 Views 0 comment Print

The Tribunal ruled that failure to formally intimate amalgamation sustained the assessment, applying Mahagun Realtors, while striking down mechanical expense disallowances.

Section 271D Penalty Quashed Because Transaction Was Accepted as Genuine

December 25, 2025 516 Views 0 comment Print

The Tribunal held that once cash received was accepted in assessment without any addition, penalty for alleged violation of Section 269SS could not be sustained.

Capital Gains Taxable Despite Gram Panchayat Certificate When Land Is Within 8 km of Municipality

December 25, 2025 687 Views 0 comment Print

The Tribunal examined whether agricultural land qualified as a non-capital asset and upheld taxation after finding it within the prescribed municipal distance. The ruling reiterates that physical verification and reliable evidence prevail over unsupported certificates.

Section 115BBE Not Applicable to Business Receipts; Only Profit on Cash Deposits Taxable

December 25, 2025 561 Views 0 comment Print

The Tribunal held that cash deposits representing trading receipts cannot be taxed in full as unexplained income. Only the estimated profit portion was directed to be assessed.

Excess Stock from Survey Taxable as Business Income, Section 115BBE Inapplicable

December 25, 2025 900 Views 0 comment Print

The Tribunal held that excess stock found during survey, when arising from regular business activity and disclosed in accounts, cannot be taxed as unexplained investment under Section 69B.

Fair Hearing Mandatory for Section 251 Income Enhancement: ITAT Amritsar

December 23, 2025 228 Views 0 comment Print

ITAT ruled that enhancement of income under section 251 without giving the assessee a proper hearing is invalid. The appeals were remanded to CIT(A) for fresh adjudication.

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