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Judiciary

Unsecured Loan Addition Unsustainable Without Contrary Evidence

January 16, 2026 444 Views 0 comment Print

The issue was whether unsecured loans from directors routed through a partnership firm could be treated as unexplained cash credits. The Tribunal held that once identity, creditworthiness, and genuineness are proved through books and bank records, section 68 addition cannot survive.

Debatable MAT Computation Cannot Be Rectified Under Section 154

January 16, 2026 243 Views 0 comment Print

The issue was whether adjustment of brought-forward loss and depreciation under MAT could be altered through rectification. The Tribunal held that such MAT computation involves interpretation and debate, making section 154 inapplicable.

Section 263 Revision Quashed for Absence of Exempt Income

January 16, 2026 222 Views 0 comment Print

The issue was whether revision could be made to examine disallowance under section 14A despite no exempt income being earned. The Tribunal held that without exempt income, the assessment was neither erroneous nor prejudicial to revenue.

Ex-Parte Appeal Dismissal Set Aside for Lack of Reasoned Order

January 16, 2026 333 Views 0 comment Print

The issue was whether the appellate authority could dismiss an appeal ex-parte without giving detailed reasons. The Tribunal held that a non-speaking order violates section 250(6) and restored the appeal for fresh adjudication.

Reassessment Quashed as JAO Lacked Jurisdiction After Faceless Scheme

January 16, 2026 1812 Views 0 comment Print

The issue was whether reassessment notices could be issued by a jurisdictional officer after the faceless reassessment scheme became mandatory. The Tribunal held that such notices are void, rendering the entire reassessment unsustainable.

Appeal Dismissed on Delay Remanded for Merits Despite Non-Compliance

January 16, 2026 978 Views 0 comment Print

The issue was whether an appeal involving large additions could be dismissed solely for delay without examining merits. The Tribunal held that technical dismissal was improper and ordered remand with costs. Key takeaway: meritorious matters should be decided on merits, not limitation alone.

Accepted Closing Cash Cannot Be Treated as Unexplained Income

January 16, 2026 267 Views 0 comment Print

The Tribunal held that once a closing cash balance is disclosed and accepted in a prior year’s scrutiny assessment, it cannot be questioned as unexplained opening cash in a subsequent year.

Appointment Denial Quashed for Ignoring Reasonable Accommodation

January 16, 2026 288 Views 0 comment Print

The Court examined whether procedural rigidity and expired panels could defeat disability rights. It held that denial of employment without reasonable accommodation violates constitutional guarantees and disability law.

Reassessment Quashed for Issuance of Notice Outside Faceless Regime

January 16, 2026 1758 Views 0 comment Print

The issue was whether reassessment could be initiated by a jurisdictional officer after faceless schemes became mandatory. The Tribunal held that notices issued outside the faceless mechanism lack jurisdiction and invalidate the reassessment.

Reopening After 3 Years Invalid If Escapement Is Below ₹50 Lakh

January 16, 2026 1425 Views 0 comment Print

Sanjay Champalal Jaiswal Vs ITO (ITAT Pune) Reopening Beyond Three Years Invalid Where Escapement Is Below ₹50 Lakh — ITAT Pune Quashes Reassessment The Pune SMC Bench of the ITAT quashed the reassessment for AY 2016-17, holding that the notice under section 148 dated 27-07-2022 was without jurisdiction, as the alleged income escaping assessment was […]

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