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Section 68 Addition Unsustainable Where Bank Trail & PAN Established: Patna High Court in Rajnandani Projects (P) Ltd. v. PCIT (2025)
Background and FactsThe Assessing Officer made an addition of ₹1.91 crore under Section
68 of the Income-tax Act, 1961, treating the amount as unexplained cash
credit. The assessee furnished complete documentary evid...
Unproved Bank Liabilities for Unpresented Cheques Treated as Bogus Credits; SLP Dismissed by Supreme Court – Harsha Associates (P) Ltd. v. DCIT
The assessee filed its return of income for Assessment Year 2007-08 declaring a total income of ₹28,71,047. The return was selected for scrutiny. During the assessment proceedings, the Assessing Officer observed that t...
Bogus Political Donations Routed Back to Donor Not Eligible for Deduction under Section 80GGC — ITAT Ahmedabad in Rajen Jayantilal Merchant v. ITO
The appeal before the Income Tax Appellate Tribunal, Ahmedabad Bench, arose from an order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, confirming the reassessment made under Sectio...
Prosecution Under Section 276C(2) Quashed for Non-Payment of Self-Assessment Tax: No Willful Evasion Established – Vilas Babanrao Kalokhe v. PCIT (Central) (Bom HC, 2025)
The assessee, engaged in the business of stone crushing and manufacturing precast cement pipes, filed the return of income for Assessment Year 2022-23 on 05.11.2022. The Assessing Officer observed that the assessee faile...
Ad Hoc 10% Disallowance of Travelling & Telephone Expenses Deleted: No Discrepancies in Audited Books – Spectrum Talent Management v. ACIT (ITAT Delhi, 2025)
The assessee-firm, engaged in providing staffing solutions and operating in the services sector, claimed travelling and telephone expenses under Section 37(1) for the relevant assessment year. The Assessing Officer obser...
No Penalty on Wife for Non-Disclosure of Joint Foreign Investment When Husband Declares in ITR: PCIT v. Aditi Avinash Athavankar (Bom. HC, 2025)
For Assessment Year 2017-18, the allegation against the respondent-assessee (wife) pertained to non-disclosure of a foreign investment in Schedule FA of her income tax return. The material on record indicated that her na...
Prosecution under Section 276C(2) Quashed for Delayed Self-Assessment Tax: No Willful Evasion Established – Vilas Babanrao Kalokhe v. PCIT (Central) [2025]
The assessee, engaged in stone crushing and manufacturing of precast cement pipes, filed the return of income for AY 2022-23 on 05.11.2022. The self-assessment tax payable under Section 140A was not discharged along with...
No Penalty for Non-Disclosure of Joint Foreign Investment When Husband Declared It: PCIT v. Aditi Avinash Athavankar (2025) – Discretion under Black Money Act Upheld
No penalty on wife for not disclosing foreign investment if husband duly declared it in his ITR
For assessment year 2017-2018, the allegation against the respondent–assessee (wife) was non-disclosure of a foreign inve...
Reassessment Limitation under New Regime: Allahabad High Court in Dinesh Jain v. Union of India Applies Rajeev Bansal (SC) to Quash Time-Barred AY 2016-17 Notice
CA. Atul Agrawal, Former Vice Chairman CIRC
31/12/2025
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| VISITOR'S COUNT: 529
Reassessment Limitation under the New Regime: Hon’ble Allahabad High Court’s First Pronouncement on the issueIn Dinesh Jain v. Union of India, the Hon’ble Division Bench of the Allahabad High Court has examined the...
Interest u/s 220(2) Not Leviable Before Fresh Section 156 Demand Notice: ITAT Mumbai in Samsara Shipping (P) Ltd. v. ITO [TS-1710-ITAT-2025(Mum)]
Levy of interest under section 220(2) for period prior to fresh demand notice under section 156, unsustainable
Mumbai ITAT allows Assessee’s appeal observing that the levy of interest under section 220(2) in the prese...