Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


City Corporation Ltd. v. Dy.CIT -(2025) 233 TTJ 367 / 170 taxmann.com 203 (Pune) ( Trib)

S. 80IB (10) : Housing projects – Assessee cannot be deprived of the benefit if the delays are beyond the control of the assessee- Matter remanded to the Assessing Officer for verification .

ACIT v. Ranu Vohra (2025) 210 ITD 285 (Mum.) (Trib.) Editorial: Pr. CIT (Central) v. Adar Cyrus Poonawalla [2018] 100 taxmann.com 227/260 Taxman 41 (Bom)(HC) followed.

S.70: Set off of loss – One source against income from another source – Same head of income – arrangement of affairs within legal framework through legitimate means to reduce its tax liability – no evidence on record to doubt genuineness of transactions – STCL derived by assessee could not be prevented from being set off against LTCG. [ S. 45 ]

Manak Chand Daga v. ITO (2025) 233 TTJ 11 (UO) (Delhi)( Trib)

S. 69C : Unexplained expenditure – Information from Investigation wing – The AO cannot proceed to disallow only the purchases in isolation and the Tribunal disallowed the purchases at 12.5%. On appeal for A.Y. 2014-15, the Tribunal observed that the Assessee had only made payments towards purchases from previous year, hence the addition for A.Y. 2014-15 was unjustified. [ S. 147 , 148 ]

Dy.CIT v. Aba Builders Ltd (2025) 233 TTJ 328/245 DTR 105 / 176 taxmann.com 216 ( Delhi)( Trib)/Dy.CIT v. IV Country ( P) Ltd (2025) 233 TTJ 328 / 245 DTR 105 / 176 taxmann.com 216 (Delhi)( Trib) Dy.CIT v. Country Infrastrctures ( P) Ltd 2025) 233 TTJ 328 / 245 DTR 105 / 176 taxmann.com 216 (Delhi)( Trib)

S. 69C: Unexplained expenditure – Search and seizure – Unabated assessment – Purchases are recorded in regular books of account- Order of CIT(A) deleting the addition is affirmed .

Turab Ali Bohra v. ACIT( 2025) 121 ITR 153 ( Jaipur )( Trib)

S. 69A: Unexplained money – Cash found in the work premises – Sales – Matter restored to AO to consider the evidence submitted. [ S. 131, 133A]

Subhash Chand Gupta v. ACIT (2025) 210 ITD 118 (Delhi) (Trib.)

S. 69A: Unexplained money- Cash deposit – Demonetisation- Cash sales – Deletion of addition is affirmed by the Tribunal . [S. 68 ]

Shankar Traders & Distributors (P.) Ltd. v. ITO (2025) 210 ITD 41 (Kol.) (Trib.)

S. 68: Cash credits -Share application- Share premium- Identity and creditworthiness and genuineness is established – Addition is deleted.

One Point Commercial Pvt. Ltd v. ITO( 2025) 121 ITR 526 (Kol)( Trib)

S. 68: Cash credits – Share capital – Share premium- Proved the identity, credit worthiness and genuineness by documents –Addition is deleted. [ S. 133(6) ]

Rajuram Savaji Purohit v. ITO [2025] 210 ITD 358 (Mum)(Trib.)

S. 68:Cash credits – Identity and creditworthiness is established -b The loan was repaid through banking channels- Addition is deleted . [ S. 147, 148 ]

Prarthana Gems v. Dy. CIT [2025] 210 ITD 158 (Surat)(Trib.)

S. 68: Cash credits -Unsecured loan- The assessee satisfactorily explained the source of the loan, and the lender’s credibility was established through the repayment in cheque and the lender’s business activity. The addition is deleted . [ S.133(6) ]