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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 252 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 111 Views 0 comment Print


ITAT Jaipur Remands ₹4.11 Crore Addition Case for Fresh Verification Due to Rule 46A Violation

November 13, 2025 252 Views 0 comment Print

Tribunal found that the CIT(A) admitted new evidence without AO’s opportunity and remanded the case for re-examination of NRE deposit sources under Section 69.

Section 54 Deduction Eligible on Actual Investment, Not Ownership Share ITAT Mumbai

November 13, 2025 696 Views 0 comment Print

Tribunal held that deduction under Section 54 depends on amount actually invested in a new property and not on ownership proportion. Assessing Officer’s restriction to 50% due to joint ownership was set aside, confirming relief for assessee.

ITAT Ahmedabad Upholds Reopening on Surrendered PAN

November 13, 2025 381 Views 0 comment Print

ITAT ruled that reassessment under section 147 is valid even if based on an old PAN, as banking and TDS records may reflect its continued use. Ex parte assessment was remanded for proper reconciliation.

Replacement Cost of Dies and Moulds is Revenue Expenditure: ITAT Mumbai

November 13, 2025 1041 Views 0 comment Print

ITAT Mumbai held that expenses on dies and moulds used in vehicle manufacturing are revenue in nature, not capital, as they involve regular replacements without creating new assets. The Tribunal upheld CIT(A)’s view, citing consistency with past rulings.

Additions under Section 69C Unsustainable When Source of Expense Is Explained

November 12, 2025 2550 Views 0 comment Print

Tribunal held that rent expense differences cannot be taxed as unexplained expenditure without questioning the source. Matter remanded for verification of reconciliation and evidence.

Assessment Order Void When Issued to Non-Existent Merged Entity: ITAT Mumbai

November 12, 2025 735 Views 0 comment Print

ITAT Mumbai ruled that once the Assessing Officer is aware of a merger, assessment in the name of the amalgamating company is invalid and without jurisdiction.

ITAT Deletes TP Adjustment as Intra-Group Services Not Stewardship Activity

November 12, 2025 573 Views 0 comment Print

ITAT Delhi held that Transfer Pricing Adjustment made by the revenue on account of administrative support services segment deserves to be deleted since services rendered are in nature of intra group services and not stewardship activity.

Only Profit on Bogus Purchases Taxable – Full Disallowance Unjustified: ITAT Mumbai

November 12, 2025 672 Views 0 comment Print

ITAT Mumbai held that doubting goods transportation alone cannot justify full disallowance, restricting the addition to 11.54% GP on ₹32.75 lakh purchases.

Bogus Purchase: ITAT Quashes 271(1)(c) Penalty as Specific Limb not Mentioned

November 12, 2025 810 Views 0 comment Print

 ITAT Mumbai deleted a penalty under Section 271(1)(c) because the notice failed to specify whether it targeted concealment of income or inaccurate particulars. The ruling highlights the need for clarity in issuing tax penalties.

Extrapolation cannot be done to assume income without any cogent material

November 12, 2025 648 Views 0 comment Print

ITAT Mumbai held that no extrapolation can be done on estimation basis in absence of any incriminating material. Accordingly, addition rightly deleted by CIT(A). Thus, order of CIT(A) upheld and appeal of revenue dismissed to that extent.

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