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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 258 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


ITAT Mumbai Quashes Reassessment as Notice Issued by Non-Jurisdictional AO

November 27, 2025 591 Views 0 comment Print

The ITAT ruled that a reassessment notice issued by a non-jurisdictional officer is void, quashing a demand of ₹1.01 crore and invalidating the assessment.

Change of Opinion Cannot Justify Reopening: ITAT Quashes 147

November 27, 2025 459 Views 0 comment Print

The ITAT Mumbai invalidated the reopening of an income-tax assessment under section 148, holding that no new tangible material was found. Interest income from co-operative banks and other receipts had already been considered in the original assessment. 

ITAT Mumbai: Corrigendum Cannot Cure Defective Section 148 Notice

November 27, 2025 447 Views 0 comment Print

ITAT Mumbai invalidated the reassessment for AY 2008-09 because the notice under section 148 was issued after the statutory limitation period and contained a clerical error in the assessment year. The ruling underscores the necessity of strict procedural compliance for reassessment.

ITAT Directs Recalculation of Capital Gains, Not Just Section 50C Difference

November 27, 2025 438 Views 0 comment Print

The Tribunal held that AO must recompute capital gains considering purchase cost, indexation, and stamp duty, instead of merely adding the section 50C deemed value difference.

Section 153A: On-Money Profit @15% Sustained, TP Addition Deleted, Bogus Purchase Confirmed

November 27, 2025 228 Views 0 comment Print

The Tribunal restricted on-money profits to 15%, deleted Transfer Pricing additions, and confirmed bogus purchase disallowances. Jurisdictional objections based on CBDT pecuniary instructions were rejected. The case provides guidance on treatment of search-assessment adjustments and substantiation requirements.

Proceedings Declared Void Due to Notice Served After Assessee’s Death

November 27, 2025 336 Views 0 comment Print

The Tribunal held the reassessment invalid since notices and the final order were issued in the name of a dead assessee despite the Department being informed. Key takeaway: assessments against deceased persons are void ab initio.

Reassessment u/s. 147 based on information without application of mind is bad-in-law

November 27, 2025 576 Views 0 comment Print

ITAT Delhi held that reopening of assessment under section 147 of the Income Tax Act, solely on the basis of information received, without application of mind is bad-in-law and liable to be quashed. Accordingly, appeal of revenue dismissed.

ITAT Remands Inventory Write-Off Dispute Due to Non-Consideration of Evidence

November 27, 2025 462 Views 0 comment Print

The Tribunal held that the appellate authority failed to examine inventory-related documents before sustaining disallowance under section 37(1). The matter was sent back for fresh adjudication with directions to consider all evidence.

Reassessment Quashed: JAO Cannot Issue Section 148 Notice After Faceless Regime

November 27, 2025 1068 Views 0 comment Print

The High Court held that reassessment notices issued by the jurisdictional officer after the faceless regime came into force were without authority. All related proceedings were quashed, and the ITAT appeal was directed to be closed as infructuous.

Demonetisation Cash Deposits Supported by Sale Deeds & Wealth Records, ITAT Limits Disallowance to 10%

November 27, 2025 471 Views 0 comment Print

ITAT Rajkot partly allowed appeal, directing that 90% of cash deposited during demonetisation be accepted as explained, with only 10% taxable under normal income tax.

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