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Judiciary

Relief for Senior Citizen: ITAT Limits Cash Deposit Addition, Cites Madras HC Ruling on 115BBE

September 27, 2025 1443 Views 0 comment Print

ITAT Delhi reduced a Rs.11.47 lakh demonetization cash addition to Rs.47,000/− for a senior citizen. Cites Madras HC ruling limiting S. 115BBE rate to transactions after 01.04.2017.

ITAT Deletes Adhoc Additions & Penalty, Allows Business Losses Despite Mis-nomenclature of Expenses

September 27, 2025 465 Views 0 comment Print

The ITAT deleted all additions and the consequential penalty, dismissing the Revenue’s appeal. It upheld the CIT(A)’s deletion of ad-hoc bogus expense additions after verifying evidence under Rule 46A.

ITAT Delhi Deletes ₹25.70 Cr FTS/FIS Additions- Marketing & Reservation Receipts Not FTS

September 27, 2025 453 Views 0 comment Print

Delhi ITAT deleted additions for Marketing/Reservation fees and Travel Agent Commission (TACP) for Six Continents Hotels. The Tribunal ruled the receipts were not FTS/FIS under the India-USA DTAA, applying the rule of consistency.

ITAT Deletes ₹30.65 Lakh Addition: Cash Gift from Grandmother Held Genuine

September 27, 2025 882 Views 0 comment Print

Delhi ITAT deleted a ₹30.65 lakh cash deposit addition made under Section 69A during demonetization. The source was proven to be a gift from the deceased grandmother’s savings of previously taxed rental income, preventing double taxation.

No Penalty u/s 271C for Late Deposit of TDS Already Deducted

September 27, 2025 1035 Views 0 comment Print

): The ITAT set aside a penalty of ₹4.25 lakh levied under Section 271C for non-deduction of TDS. Citing the Supreme Court ruling in U.S. Technologies International Pvt. Ltd., the Tribunal held that Section 271C applies only to the failure to deduct, not the late remittance of already deducted tax.

SFIO Report Alone Cannot Justify Massive ₹1000 Cr Addition: ITAT Remands

September 27, 2025 4083 Views 0 comment Print

Delhi ITAT deleted a Rs.1000 crore addition made under Section 68 based solely on an SFIO report alleging circular fund rotation. The Tribunal upheld reopening but limited the addition to estimated commission income, ensuring parity with group cases.

Assessment in Name of Deceased Not Void if Notice Issued During Lifetime

September 27, 2025 870 Views 0 comment Print

The ITAT ruled that a reassessment order passed in the name of a deceased assessee is a curable irregularity, not void ab initio, provided the initial Section 148 notice was validly issued during the assessee’s lifetime.

Omission to Disallow Interest on Unexplained Loans is Error – 263 Jurisdiction Valid

September 27, 2025 366 Views 0 comment Print

ITAT Ahmedabad upheld PCIT’s revisionary order, ruling that AO’s failure to disallow interest (Rs.44.51 lakh) on unsecured loans (Rs.92 lakh) already deemed unexplained was an erroneous and prejudicial’ omission, not merely a difference of opinion.

ITAT Allows Fresh Evidence on Unsecured Loans, Remands Assessment

September 27, 2025 375 Views 0 comment Print

ITAT Chennai admitted fresh documents including confirmations and bank statements for unsecured loans and advances, remanding the matter to AO for de novo assessment to ensure natural justice.

ITAT Ahmedabad Quashes ₹3.68 Cr Additions Based on WhatsApp & Loose Sheets

September 27, 2025 609 Views 0 comment Print

The Income Tax Appellate Tribunal (ITAT) upheld the CIT(A)’s ruling, deleting unexplained money and commission additions made against Riddhesh Girishbhai Bhandari following a search.

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