Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


ITO v. Kalidas Jivabhai Patel (2025) 237 TTJ 95 (Ahd)(Trib)

S. 69: Unexplained investments-Capital introduced by partner-The explanation furnished by the assessee cannot be rejected merely on suspicion-Order of CIT(A) deleting the addition was affirmed.

ACIT v. Double Plus Software (P) LTD. (2025) 237 TTJ 769 (TM) (Delhi) (Trib.)

S. 68: Cash credits-Share capital-Addition already made in the hands of investor companies-Amount cannot be taxed again in the hands of the assessee company as the Act does not envisage taxation of the same income twice over on one passage of money.

Kumar Urban Development (P) Ltd. v. DCIT (2025) 237 TTJ 881 (Pune) (Trib.)

S. 68: Cash credits-Advance received from customers of the housing project-Offered to tax such advances received in the subsequent years-Addition was not justified-Entitled to claim deduction under s. 80-IA-Addition was rejected. [S. 80IA]

Peeyush Agarwal v. ITO (2025) 237 TTJ 515 (Jaipur)(Trib)

S. 68: Cash credits-Cash deposits-Demonetization-Survey-Cash sales accepted-Auditors have certified that proper books of account as required by law have been kept by the assessee and books of account give a true and fair view of profit-The rejection of the books of account by the CIT(A) was held to be not justified-Addition was deleted. [S. 69A, 133A, 145(3)]

ITO v. Somila Texfab (INDIA) (P) LTD. (2024) 237 TTJ 333 (Jodhpur)(Trib)

S. 68: Cash credits-Difference between amount of loan shown in audit report and confirmation-Filed confirmation-two separate account-Deletion of addition was affirmed.

ITO v. Evexia Lifecare Ltd. (2025) 237 TTJ (Ahd) 1(Ahd)(Trib)

S. 68: Cash credits-Share application money-On account of convertible equity warrants from companies which are operated by an entry operator –AO was justified in treating the amount as unexplained income of the assessee. [S. 131(IA) 132(4),133(6)]

DCIT v. Aathmika Holdings (P) Ltd. (2025) 237 TTJ 943 / 176 taxmann.com 1001 (Chennai)(Trib)

S. 56: Income from other sources-Fair market value of shares acquired by assessee from AE-The assessee purchased the shares of ETL at Rs. 14.30 per share, which is higher than its FMV-Even if the assessee has obtained the valuation report at a later date, as long as it is able to demonstrate that the FMV has been ascertained in accordance with R. 11UA(1)(c) based on audited balance sheet drawn up on the valuation date, said report cannot be rejected for being obtained post the date of transaction-CIT(A) was justified in deleting the addition made under s. 56(2)(x)[S.56(2)(x), R.11UA(1)(c)]

Ipsaa Holdings (P) LTD. v. ACIT (2025) 237 TTJ 605 / 176 taxmann.com 823 (Delhi)(Trib)

S. 56: Income from other sources-Issue of shares at a premium-DCF method-Addition was deleted. [S. 56(2)(vii), R.11UA]

ITO v. Somila Texfab (INDIA) (P) LTD. (2024) 237 TTJ 333 (Jodhpur)(Trib)

S. 56: Income from other sources-Issues of shares at premium-The valuation of share determined by the chartered accountant at Rs. 15.23 per share was held to be correct and the addition made by the AO under s. 56(2)(viib) was deleted. [S.56(2)(viib)]

Deepak Kothari v. ACIT (2025) 237 TTJ 241 / 177 taxmann.com 219 (Delhi) (Trib)

S. 56: Income from other sources-Receipt of bonus shares-Provisions of s. 56(2)(vii)(c) are not attracted on receipt of bonus shares.[S.56(2)(vii)(c)]