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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


Addition Partly Deleted as ITAT Finds Loan Withdrawals Linked to Cash Deposits

November 25, 2025 651 Views 0 comment Print

The Tribunal held that the timing of loan disbursals and demonetization supported the assessee’s explanation. Key takeaway: partial relief granted by accepting most of the deposit as explained.

Share Capital Call-Money ₹2.10 Cr Deletion u/s 68; ITAT Upholds Genuineness

November 24, 2025 393 Views 0 comment Print

ITAT Delhi deletes ₹2.10 Cr addition u/s 68 for share call-money; statements not supplied or cross-examined. Identity, creditworthiness & genuineness of subscribers proven; ad-hoc disallowance also deleted.

Penalty u/s 271(1)(c) Cannot Survive When Quantum Itself Is Remanded

November 24, 2025 1062 Views 0 comment Print

 ITAT held that penalty under Section 271(1)(c) cannot survive when the underlying addition is remanded, directing the AO to re-decide the penalty after the quantum order is finalized.

AO Cannot Replace DCF with NAV Simply Due to Projection Variances

November 24, 2025 411 Views 0 comment Print

The case examined whether the tax officer was justified in rejecting the assessee’s DCF-based share valuation under Section 56(2)(viib). The Tribunal held that once DCF is chosen, the AO cannot switch to NAV merely because subsequent financials differ from projections

Deduction u/s 80-O was allowable on Overseas Advisory Services rendered from India

November 24, 2025 471 Views 0 comment Print

Professional and technical advisory services rendered from India to foreign clients in connection with overseas securities offerings qualify for deduction under Section 80-O as there was coordinate Bench’s decision in the assessee’s own case for AY 1995-96

Set-Off of LTCL & STCL Against LTCG Cannot Be Denied Merely Because Tax Rates Differ

November 23, 2025 3405 Views 0 comment Print

ITAT Delhi permits set-off of brought forward long-term and current year short-term capital losses against long-term capital gains, overruling CPC and CIT(A).

ITAT Upholds 14A Satisfaction but Limits Rule 8D to Dividend Investments

November 22, 2025 369 Views 0 comment Print

The Tribunal directed AO to compute Section 14A disallowance only for investments generating exempt income, following Rule 8D. The decision reinforces the need for precise calculation of disallowances against exempt income.

ITAT Remands CIT(A) Order for Non-Speaking Decision on 54/54F & Net Consideration

November 22, 2025 891 Views 0 comment Print

Tribunal found the appellate order non-speaking, failing to consider multiple submissions including 54F claims and compensation deductions. The matter is remanded for comprehensive review and proper opportunity of hearing.

ITAT Restores Appeal After NFAC Rejected Rectification Due to Portal Visibility Error

November 22, 2025 540 Views 0 comment Print

CIT(A) wrongly rejected the assessee’s rectification petition under section 154 despite portal evidence. ITAT restored the appeal for fresh adjudication with full opportunity to submit evidence.

ITAT Orders AO to Examine Additional Section 54B Claim Omitted in Return

November 22, 2025 297 Views 0 comment Print

ITAT rules that an additional 54B claim omitted in the original return cannot be mechanically rejected. AO must examine the claim on merits, verifying capital gains utilisation and statutory conditions.

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