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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 270 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 123 Views 0 comment Print


ITAT Mumbai Quashes Reopening Beyond 3 Years for Sanction by Wrong Authority

December 18, 2025 552 Views 0 comment Print

The tribunal held that a reassessment notice issued after three years was invalid as sanction was taken from an incompetent authority. The assessment was quashed for non-compliance with section 151(ii) of the Income Tax Act.

Section 80P(2)(d) Deduction Allowed on Interest from Co-operative Bank Deposits: ITAT Surat

December 17, 2025 567 Views 0 comment Print

The Tribunal upheld deduction under Section 80P(2)(d) where interest income was earned from deposits with a co-operative bank. It held that a co-operative bank remains a co-operative society for this purpose.

Delay of filing of appeal before CIT(A) not condoned as sufficient cause not shown

December 17, 2025 612 Views 0 comment Print

ITAT Indore held that delay of 560 days in filing of an appeal before CIT(A) rightly not condoned as assessee has failed to give satisfactory and bonafide explanation. Accordingly, delay not condoned as no sufficient cause shown.

Rs. 113.46 Crore Section 68 Addition Fails Due to Jurisdictional Defect

December 17, 2025 744 Views 0 comment Print

The issue was whether an Assessing Officer can travel beyond limited scrutiny without mandatory approval. The Tribunal held that such action violates binding CBDT Instructions and renders the assessment void from inception

Transfer Pricing Assessments Quashed as Time-Barred Despite DRP Directions

December 17, 2025 603 Views 0 comment Print

The tribunal held that assessments completed through the DRP mechanism remain subject to the outer time limit prescribed under section 153. The key takeaway is that section 144C does not extend or override statutory limitation periods.

No Further Section 14A Disallowance After Reasoned Suo-Motu Adjustment

December 16, 2025 582 Views 0 comment Print

The ITAT held that where investments are fully backed by substantial own funds and a rational suo-motu disallowance is made, Rule 8D cannot be mechanically invoked. The Revenue’s attempt to make an additional disallowance was rejected.

Estimated Gross Profit Addition Collapses When Excess Stock Is Not Proved

December 16, 2025 291 Views 0 comment Print

The Tribunal held that a surrender during survey cannot justify additions without supporting material. Statements under Section 133A lack evidentiary value unless backed by records. Additions based solely on surrender were deleted.

ITAT Rejects Business Parlance Test in Section 56 Application

December 16, 2025 453 Views 0 comment Print

The ITAT held that even a small part payment through banking channels before or on the agreement date is sufficient to invoke the provisos to section 56(2)(vii)(b)(ii). Substantial payment or possession is not a statutory requirement.

DRP Route Cannot Extend Statutory Time Limit Under Section 153

December 16, 2025 609 Views 0 comment Print

The Tribunal held that a final assessment passed after the expiry of Section 153 is invalid, even if it follows DRP directions. The is that limitation under Section 153 remains mandatory and cannot be bypassed through the DRP route.

Section 68 Addition Fails Where AO Makes No Inquiry: Unsecured Loans Accepted

December 15, 2025 1161 Views 0 comment Print

The ITAT held that unsecured loans totaling ₹1.05 crore could not be added under Section 68 where the AO failed to make any inquiry or issue summons, emphasizing that suspicion alone cannot justify additions.

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