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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 327 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 66 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


Vague Penalty Notice Invalid: ITAT Deletes 200% Penalty Under Section 270A

April 3, 2026 195 Views 0 comment Print

The Tribunal ruled that failure to specify underreporting or misreporting in notice invalidates penalty. Proper identification of charge is mandatory for valid proceedings.

Reassessment Quashed as Notice Beyond 3 Years Approved by Wrong Authority

April 3, 2026 288 Views 0 comment Print

ITAT held that reassessment initiated with approval from the wrong authority is invalid when issued beyond three years. The entire proceedings were quashed. The key takeaway is that proper sanction under Section 151 is mandatory.

8% Profit Estimate Cut to 3%: AO Ignored Books & Industry Reality

April 3, 2026 408 Views 0 comment Print

ITAT held that estimating profit at 8% without considering records was excessive. It reduced the rate to 3% based on business realities. The key takeaway is that estimation must be reasonable and evidence-based.

Delay Condoned for FTC Claim: Pursuing Rectification is Valid Cause

April 3, 2026 129 Views 0 comment Print

The Tribunal condoned a delay of 615 days after finding that the assessee was actively pursuing rectification remedies under Section 154. It held that such bona fide conduct constitutes sufficient cause and delay cannot be treated as negligence.

11-Year Delay Not Condoned: Mere Rectification Plea No Excuse

April 3, 2026 198 Views 0 comment Print

ITAT held that an unexplained delay of over 11 years cannot be condoned without valid reasons. The appeal was dismissed as no sufficient cause was proved.

FTC Cannot Be Denied for Late Form 67: Substantive Right Prevails

April 3, 2026 144 Views 0 comment Print

ITAT held that late filing of Form 67 is only a procedural lapse and not a ground to deny FTC. The matter was remanded for verification and grant of eligible credit.

Agricultural Land Capital Gain Addition Deleted in absence of development or trading intent

April 3, 2026 654 Views 0 comment Print

The issue involved denial of exemption on sale of agricultural land. The Tribunal held that the land met conditions of Section 2(14)(iii), making gains non-taxable. The case examined whether land sale constituted business income. The Tribunal ruled that absence of development or trading intent invalidated such classification.

Reassessment Fails When Original Reason Disappears – ITAT Chennai Quashes Entire Proceedings

April 2, 2026 852 Views 0 comment Print

The issue was whether reassessment can survive when no addition is made on the stated reasons for reopening. The Tribunal held that such reassessment is invalid, and the AO cannot make unrelated additions.

Allotment Letter = Agreement-ITAT Grants 56(2)(x) Relief, Limits Addition to 50% Share

April 1, 2026 309 Views 0 comment Print

The tribunal set aside excessive addition by recognizing both the allotment agreement and joint ownership. It directed proportionate taxation and correct valuation basis. The ruling promotes fairness in assessments.

Section 50C Applies to Leasehold Rights; But Stamp Value to Follow Agreement Date-ITAT Grants Major Relief

April 1, 2026 132 Views 0 comment Print

The tribunal allowed adoption of stamp value as on the agreement date instead of registration. It held the proviso to Section 50C is retrospective as it removes hardship. This provides relief in cases of delayed registration.

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