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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


Provision for Salary Arrears Held Allowable When Made Pursuant to Court Order: ITAT Guwahati

October 30, 2025 486 Views 0 comment Print

The Tribunal upheld that a provision made for arrears of VDA, PFD, and HRA pursuant to a High Court directive represented a crystallized liability. Since the assessee’s obligation was judicially enforceable, the expenditure was allowable. Disallowance was correctly limited to 30% under Section 40(a)(ia) for TDS non-compliance.

No Depreciation on Assets Already Treated as Applied Income: ITAT Directs Fresh Verification

October 30, 2025 513 Views 0 comment Print

 The ITAT Chennai restored a trust’s appeal to the AO to verify if the asset’s cost was allowed as application of income before disallowing depreciation under Section 11(6) of the Income Tax Act.

ITAT Mumbai Upholds Depreciation on Goodwill Arising from Amalgamation

October 30, 2025 537 Views 0 comment Print

ITAT Mumbai dismisses Revenues appeal, ruling that Goodwill from a High Court-approved amalgamation is a depreciable intangible asset under Section 32, rejecting the claim that it represents non-depreciable land value.

Capital Contribution for Business Purposes Not Deemed Dividend u/s 2(22)(e)

October 30, 2025 720 Views 0 comment Print

ITAT Surat rules company’s capital contribution to a partnership firm for business purposes is not a loan or advance, thus escaping deemed dividend tax u/s 2(22)(e).

Disallowance of 20% on expenditure payments was justified based on lack of proof and documentation for sub-contractor payments

October 29, 2025 390 Views 0 comment Print

AO was wrong in disallowing the entire direct expenditure claimed towards sub-contractors for stevedoring and transport services and at the same time, assessee had not proved beyond doubt that the expenditure claimed was fully genuine. Considering all these inconsistencies, CIT(A) righlyl disallowed 20% of the expenditure claimed.

Best Judgment u/s 144 & 8% Profit Estimation in Poultry Case Set Aside for Fresh Hearing

October 28, 2025 699 Views 0 comment Print

The ITAT Pune set aside a best judgment assessment (u/s 144) that arbitrarily estimated an 8% net profit for a poultry farm and disallowed interest expense. The Tribunal ruled that substantive justice requires a fresh adjudication, remanding the case to the AO to allow the assessee a fair chance to present audited books and evidence.

Section 153C: Block Period to Be Counted from Date of Material Receipt, Not Date of Search

October 28, 2025 717 Views 0 comment Print

The dispute was the computation of the block period under S 153 for a non-searched person, where the AO counted the period from the search date. The ITAT affirmed the quashing of the assessment, ruling that the block period must be reckoned from the date the seized material is received by the jurisdictional AO, as per binding Supreme Court precedent.

Typo Triggered ₹7.86 Cr Addition: Return Remanded for Re-Examination

October 28, 2025 465 Views 0 comment Print

The case addressed the disallowance of Rs.7.86 Cr treated as unexplained cash credit due to a sharp increase in proprietor’s capital shown in the tax return. The ITAT set aside the addition, finding a prima facie case of mere misclassification of partner overdrawn balances as capital, which should not be automatically treated as new unexplained income under S 68.

Payments to Partner NGOs is Application of Income: ₹1.89 Cr Addition Deleted by ITAT Delhi

October 28, 2025 417 Views 0 comment Print

The case addressed the disallowance of Rs.1.89 Cr, which the AO treated as a donation to other trusts and deemed income under S 11(3). The ITAT deleted the addition, ruling that payments made to other NGOs for executing charitable projects under the Trust’s supervision and control constitute genuine application of income, not donation.

₹6.88 Crore Additions Invalid as Reassessment Void Without 143(2) Notice: ITAT Delhi

October 28, 2025 462 Views 0 comment Print

The central issue was the validity of a reassessment that led to additions for bogus purchases and unexplained cash. The ITAT confirmed the entire reassessment was void because the AO failed to issue the mandatory notice under S 143(2), affirming the deletion of all additions.

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