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Judiciary

CIT(A) Cannot Set Aside Case After Favorable Remand Report: ITAT Delhi

January 15, 2026 375 Views 0 comment Print

The Tribunal ruled that setting aside a best-judgment assessment after admitting additional evidence and remand findings is unjustified. CIT(A) must decide the case conclusively instead of granting a fresh lease to the AO.

Reassessment Issued to Deceased Person Held Void Ab Initio

January 15, 2026 588 Views 0 comment Print

The Tribunal held that a reassessment notice issued years after the assessee’s death is a legal nullity. Such proceedings are void even if the department was not informed about the death.

271D/271E Penalties Time-Barred: Limitation Runs from AO’s Action, Not Addl. CIT Notice

January 15, 2026 909 Views 0 comment Print

Applying settled law, the Tribunal held that penalties imposed after expiry of the limitation period are void. Both loan and repayment penalties were deleted across multiple years.

Form 26AS Mismatch Alone Can’t Justify Income Addition: ITAT Mumbai

January 15, 2026 1179 Views 0 comment Print

Mumbai ITAT held that additions cannot be sustained merely due to Form 26AS mismatches. The Assessing Officer must verify whether income was already taxed to avoid double taxation.

Accommodation Entry Cases: Full Addition Applies Without Proof

January 15, 2026 1248 Views 0 comment Print

Mumbai ITAT held that unexplained bank credits are fully taxable under Section 68 when beneficiaries of accommodation entries are not identified. Mere claim of acting as an entry operator does not limit addition to commission income.

Borrowed Satisfaction from Investigation Wing Not Permissible

January 15, 2026 1047 Views 0 comment Print

The Tribunal ruled that reassessment based on borrowed satisfaction, without inquiry or verification by the AO, is unsustainable. Independent application of mind is mandatory under the new regime.

Block of Assets Continues If New Asset Added Before Year-End: ITAT Mumbai

January 15, 2026 351 Views 0 comment Print

ITAT Mumbai held that a block of assets does not cease if a new asset is added before 31 March. Consequently, no short-term capital gain under Section 50 can be levied.

ITAT Upholds 5% Addition Where Purchases Linked to Sales

January 15, 2026 297 Views 0 comment Print

The Tribunal confirmed that once goods are shown to be sold, purchases cannot be treated as wholly fictitious. A limited addition to cover possible inflation was held justified.

Cash Deposit Reassessment Set Aside for Lack of Valid Sanction: ITAT Delhi

January 15, 2026 1491 Views 0 comment Print

Despite large additions for alleged unexplained cash deposits, the Tribunal quashed the reassessment itself. It reaffirmed that jurisdiction cannot be assumed without proper and reasoned approval.

LTCG on Firm Dissolution Sent Back for Fresh Verification

January 15, 2026 468 Views 0 comment Print

The Tribunal held that deletion of long-term capital gains without examining original partnership records was premature. The matter was remanded for fresh verification of facts and documents.

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