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Judiciary

Profit Estimated as Safeguard; Bulk Cash Credit Addition Set Aside

December 21, 2025 327 Views 0 comment Print

The Tribunal upheld deletion of additions where receipts were linked to declared sales and no evidence of cash back was shown. Acceptance of sales negates Section 68 in the absence of proof.

ITAT Grants Last Chance in ₹2.28 Cr Unexplained Property Investment Case

December 21, 2025 240 Views 0 comment Print

ITAT Ahmedabad remanded a ₹2.28 crore unexplained property investment case to the AO, allowing the assessee one final opportunity to provide supporting documents, while imposing a ₹5,000 cost for non-compliance.

Interest from Private Banks Eligible for 80P Deduction: ITAT Pune Clarifies

December 21, 2025 504 Views 0 comment Print

ITAT Pune ruled that interest earned by a cooperative society from ICICI and HDFC banks retains its character as business income and qualifies for deduction under section 80P(2)(a).

Illiteracy and Notice Errors Save ₹2.61 Cr in ITAT Delhi Ruling

December 21, 2025 312 Views 0 comment Print

ITAT Delhi overturned a ₹2.61 crore addition under sections 144/147, noting notices were sent to the wrong address and the illiterate assessee was deprived of proper hearing.

Single Section 153D Sanction for Seven Years Deemed Illegal by ITAT

December 21, 2025 627 Views 0 comment Print

The ITAT Delhi ruled that a single approval for seven assessment years under Section 153D, issued without application of mind, is invalid, quashing the related assessment orders. The case underscores the need for careful, year-specific scrutiny.

Section 153C Notice Invalid Due to Missing ₹50 Lakh Asset Satisfaction

December 21, 2025 435 Views 0 comment Print

Upholding the appellate authority, the Tribunal confirmed that jurisdiction cannot be assumed casually against a non-searched person. Statutory satisfaction requirements are mandatory, not procedural.

Section 148 Notice by Local AO Invalid Under 2022 Scheme

December 21, 2025 630 Views 0 comment Print

The Tribunal held that notices issued under Section 148 must follow the faceless mechanism prescribed by the CBDT Scheme, 2022. Issuance by the Jurisdictional Assessing Officer instead of the Faceless Assessing Officer vitiated the proceedings.

Execution of Specific Performance Decree Restored Despite Delay in Deposit

December 21, 2025 702 Views 0 comment Print

The Supreme Court held that delay in filing execution and depositing balance sale consideration does not by itself render a decree inexecutable. Readiness and willingness, not rigid timelines, remain the decisive test.

Section 148A Proceedings Invalid Outside Section 151A Framework

December 21, 2025 477 Views 0 comment Print

The Court held that reassessment initiated outside the statutory framework of Section 151A is invalid. All notices and approvals issued by the jurisdictional officer were quashed, with liberty reserved for revival.

Bogus Loan Allegation Rejected After Proof of Repayment

December 21, 2025 681 Views 0 comment Print

The issue was whether unsecured loans could still be treated as unexplained after repayment. The Tribunal held that once repayment is recorded by the AO, the addition is unsustainable.

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