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Judiciary

CBDT Memorandum Not Conclusive Proof of Bogus Donation

January 6, 2026 480 Views 0 comment Print

The AO disallowed a weighted deduction relying only on a subsequent CBDT list. ITAT ruled that factual verification and proof of bogus donation are mandatory before denying the claim.

Extrapolation Without Evidence Invalid, ₹77.27 Lakh Deletion Upheld

January 6, 2026 375 Views 0 comment Print

The issue was whether an extrapolated SCO value could justify unexplained investment in the buyer’s hands. ITAT held that once the seller’s extrapolation was rejected, the buyer’s addition could not survive.

Agricultural Cash Deposits Not Entire Income, Only Profit Taxable

January 6, 2026 966 Views 0 comment Print

The Assessing Officer treated full bank deposits as unexplained income under section 69A. The Tribunal ruled that agricultural turnover cannot be taxed entirely and allowed only an estimated 10% addition.

ITAT Visakhapatnam Quashed Reassessment as Notice Was Issued by Wrong Authority

January 6, 2026 630 Views 0 comment Print

Gattula Lakshmi Madhavi Vs ACIT (ITAT Visakhapatnam) Central Circle Cannot Assume Reassessment Powers — Section 148 Notice Issued Outside Faceless Regime Held Void The Visakhapatnam Bench of the ITAT quashed the reassessment framed under Section 147 and consequential penalties under Sections 270A and 271AAC in the case of Gattula Lakshmi Madhavi v. ACIT, holding that […]

PF/ESI Due Date Verification Incomplete, Matter Sent Back to AO

January 6, 2026 282 Views 0 comment Print

The issue centered on employees’ PF contributions and statutory due dates post-Checkmate ruling. The ITAT held that detailed verification was still required, warranting remand.

Notice Issued Via ITBA After 01-04-2021 Triggers New Reopening Law

January 6, 2026 609 Views 0 comment Print

The issue was whether a notice dated 31-03-2021 but digitally signed on 01-04-2021 was valid. The ITAT held the notice was issued under the new regime without following section 148A, rendering reassessment void.

AY 2015-16 Reassessment Void as Post-2021 Notices Are Time-Barred

January 6, 2026 654 Views 0 comment Print

The AO added ₹1 crore based on alleged cash receipts from third-party material. The Tribunal held the reopening itself was invalid, so the addition could not survive.

One Surviving Predicate Accused Keeps PMLA Action Alive

January 6, 2026 891 Views 0 comment Print

The issue was whether property attachment under PMLA survives after discharge of some accused. The Tribunal held that as long as the scheduled offence continues against a principal accused, attachment of properties cannot be lifted.

Section 148 Notices for AY 2015-16 Invalid Under New Regime

January 6, 2026 1389 Views 0 comment Print

The AO issued reassessment notices during the post-Ashish Agrawal transition phase. Applying later Supreme Court law, the ITAT held AY 2015-16 is beyond the permissible reopening period.

Cheque Payment Claim Rejected, ED Proves Layering of Crime Proceeds

January 6, 2026 504 Views 0 comment Print

The appellants argued that old properties could not be attached under PMLA. The Tribunal rejected this, holding that “value of proceeds of crime” covers such assets when tainted funds are unavailable.

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