Author: ksalegal

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Jagjit Singh Kataria v. PCIT (2025) 233 TTJ 1 / 245 DTR 49 (Delhi)(Trib)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Enhanced compensation granted under the Land Acquisition Act, 1894-Assessing Officer treated as exempt-Jurisdictional High Court held as taxable-Revision order is affirmed. [S. 10(37), 56(2)(viii), Land Acquisition Act, 1894, 28, 34]

Ganesh Builders v. PCIT (2025) 233 TTJ 257 (Jodhpur)(Trib)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Survey-AO raised specific queries-Revision order is quashed.[S. 133A]

Finova Capital (P) Ltd. v. PCIT 2025) 233 TTJ 699 (Jaipur)(Trib)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Consultation fees in the form of syndication fees for raising Convertible Cumulative Preference Shares-The AO has taken a plausible view-Revision order is set aside. [S. 143(3)]

Anabond Ltd. v. PCIT (2025) 233 TTJ 761 / 246 DTR 32 (Chennai)(Trib)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Expenditure on scientific research-Conducted detailed enquiries into claim of deduction-Revision order is quashed. [S. 35(2AB), 143(3)]

Indu Sharma (Smt.) v. ITO (2025) 233 TTJ 113 (Amritsar)(Trib)

S. 251 : Appeal-Commissioner (Appeals)-Powers-Dismissal of appeal ex parte-CIT(A)has no power to dismiss the appeal without discussing the appeal on merits-Matter is remanded to the CIT(A) to decide the grounds on merits. [S. 250(1)]

Ritika Jain v. ITO (2025) 233 TTJ 619 / 245 DTR 377 (SMC) (Agra)(Trib)

S. 249 : Appeal-Commissioner (Appeals)-Form of appeal and limitation-No admitted income-Cash deposited in the Bank-The proviso also provides that when there is good and sufficient reasons, then the appeal can still be admitted-Matter is restored to the CIT(A) to adjudicate the appeal on merits in accordance with law. [S. 69A, 249 (4)(b), 250]

Dy.CIT v. Vamsi Mohan Vallabhaneni (2025) 233 TTJ 121 / 245 DTR 81 (Hyd)(Trib)

S. 153C : Assessment-Income of any other person-Search year-Wrongly applied the provision of Section 153C by the CIT(A) matter is remanded to the file of CIT(A) to deecide the issue on merits-Application for adjournment is rejected. [S. 132, 143(3)255, ITAT R,1963, R. 23]

Shrigopal Rameshkumar Sales (P) Ltd. v. Dy.CIT (2025) 233 TTJ 747 / 246 DTR 51 (Nag)(Trib)

S. 153A: Assessment-Search-Undisclosed income-Document referred to and relied upon by the AO does not bear any signature of the assessee-Addition is deleted-Appellate Tribunal-Delay of 702 days in filing the appeal is condoned. [S. 254(1)]

Asha Daga v. Dy.CIT (2025) 233 TTJ 860/ 170 taxmann.com 199 (Raipur)(Trib)

S. 153A: Assessment-Search-Approval-Jt. CIT has given certain specific instructions to the AO- Mandate is complied with.[S. 143(3)153D]

Pushpadevi Shivlal Rathi v. ITO (2025) 233 TTJ 12 / 245 DTR 16 (SMC) (Pune) (Trib)

S. 148 : Reassessment-Notice-Limitation-First notice under s. 148 was issued on 30th June, 2021-Since the notice was issued after 1st April, 2021, amended provisions effective from 1st April, 2021 were applicable-Notice is within limitation period. [S. 147, 148A(d)]