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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 342 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


Courses not having any approval with any authority cannot be reason to deny benefit u/s. 11

December 11, 2025 291 Views 0 comment Print

ITAT Mumbai held that courses not having any approval or affiliation with any authority cannot be ground to hold that the purpose is not charitable. Accordingly, benefit of exemption under section 11 of the Income Tax Act granted since activity of imparting education within meaning of section 2(15).

CIT(A) Cannot Set Aside Every Section 144 Order Automatically—Addition Deleted After AO Confirms Reconciliation

December 11, 2025 711 Views 0 comment Print

Tribunal clarified that the Section 251 amendment uses the term ‘may set aside,’ meaning it is discretionary. Since the issue was already resolved in remand, addition was deleted.

Manual Section 148 Notices Violate CBDT Escaping Assessment Scheme

December 10, 2025 507 Views 0 comment Print

The ITAT held that reassessment notices must be issued through NFAC under the 2022 Faceless Scheme. A JAO-issued notice violates the mandatory procedure and stands invalid.

Non-Speaking CIT(A) Order Quashed; IDS & JDA Issues Re-Examined

December 10, 2025 192 Views 0 comment Print

Tribunal quashed CIT(A)’s cryptic order that upheld addition based solely on IDS declaration. The case is remanded to ensure a fair hearing, full analysis of the Joint Development Agreement, and accurate determination of tax liability.

Non-Speaking Order Set Aside – ITAT Sends ₹7.26 Cr Capital-Gain Dispute Back to CIT(A)

December 10, 2025 150 Views 0 comment Print

The Tribunal held that the CIT(A) failed to give a reasoned order on land ownership and capital-asset status. The case is remanded for fresh adjudication and proper hearing.

CIT(A) Mistaken on VSVS Leads ITAT to Remand Quantum Appeal

December 10, 2025 327 Views 0 comment Print

The Tribunal held that CIT(A) misinterpreted a VSVS 2020 declaration for penalty as covering quantum, dismissing the appeal without considering merits. The order was set aside, and the matter remanded for de-novo adjudication. Quantum issues must be assessed independently of VSVS for penalties.

Double Taxation Prevented: Tribunal Deletes Addition as Cash Sales Already Recorded

December 10, 2025 315 Views 0 comment Print

ITAT held that cash sales forming part of disclosed turnover cannot be taxed again as unexplained cash credits. The ruling confirms that Section 68 does not apply when books are intact and evidence supports the sales.

Commission-Based Business Proven: Tribunal Rejects Section 44AD and Upholds 5% Profit Rate

December 10, 2025 489 Views 0 comment Print

ITAT held that the assessee operated as a commission agent, not a trader, making Section 44AD inapplicable. A reasonable 5% estimation on cash deposits was upheld.

₹3.32 Cr 69A Addition Remanded as Legal Grounds Not Examined

December 10, 2025 243 Views 0 comment Print

The ITAT ruled that unresolved legal grounds—especially on reassessment validity—must first be decided by the CIT(A). The ₹3.32 crore Section 69A addition is remanded for proper adjudication.

ITAT Cuts Additions from Rs.13.91 Lakh to Rs.1.39 Lakh Using 10% Estimate

December 10, 2025 162 Views 0 comment Print

The Tribunal held that the AO found no fabricated or false documents for agricultural or tuition income. Since evidence existed but was incomplete, ITAT applied a 10% estimate and cut the addition drastically.

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