This Digest of case laws is prepared by KSA Legal and AIFTP from judgements reported in BCAJ, CTR, DTR, ITD, ITR, ITR (Trib), Chamber's Journal, SOT, Taxman, TTJ, BCAJ, ACAJ, www.itatonline.org and other journals
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S. 194IA : Deduction at source-Purchase of property-Two sellers-Consideration below Rs. 50 lakhs individually-No TDS liability-Interest deleted [S. 201(1)]

Archanaben Rajendrasingh Deval v. ITO (2025) 212 ITD 414 (Ahd)(Trib.)

S. 164:Representative assessees-Charge of tax-Beneficiaries unknown-Trusts created by Will are not to be subjected to tax at Maximum Marginal Rate (MMR) but are to be taxed at rates applicable to AOPs. [S.143(1)(b), 160, 161(IA), 164(1),167B]

Nathiben Kalidas Patel Family Trust. v. ITO (2025) 212 ITD 539 (Ahd) (Trib.)

S. 164 : Representative assessee-Discretionary trust-Maximum marginal rate-Surcharge to be computed with reference to slab rates under Finance Act. [S. 2(29C), 111A, 112A, 167B, Finance Act, 2023]

Araadhya Jain Trust v. ITO (2025) 212 ITD 1 (SB)(Mum)(Trib.)

S. 151 : Reassessment-Sanction for issue of notice-Beyond three years-Approval by Principal Commissioner invalid-Reassessment quashed [Ss. 147, 148, 148A(b), 151(i), 151(ii)]

DCIT v. SS Jewellery (2025) 212 ITD 432 (Mum)(Trib.)

S. 147 : Reassessment-Vehicle hiring charges-Specific query was raised in the assessment proceedings-Reassessment is quashed. [S. 11, 13(1)(c), 13(3)(cc), 143(3)]

Saraswati Mukund Education Society. v. ITO (2025) 212 ITD 142 (Mum) (Trib.)

S. 147: Reassessment-Industrial undertakings-Lower deduction in original return-Higher deduction in response to notice u/s 148-Deduction cannot be denied. [S.80IA, 148]

Bharat Mithalal Jain. v. ITO (2025) 212 ITD 232 (Mum) (Trib.)

S. 147 : Reassessment-Information from DIT (Inv)-Beneficiary of accommodation entries-Long term capital gains-Sale of shares-Vague reasons recorded-Borrowed satisfaction-Sanction-Mechanical approval-Reassessment was quashed. [S.69A, 143)(1), 148, 151]

Anju Daruka v. ITO (2025) 212 ITD 326 (Kol) (Trib.)

S. 144C : Reference to dispute resolution panel-Revised direction of DRP-Rectification order-Assessing Officer is directed to consider rectified direction of DRP and corresponding revised giving-effect order of TPO and delete entire TP adjustment. [S.92C, 154]

Ariba Technologies India (P.) Ltd. v. DCIT (2025) 212 ITD 17 (Bang) (Trib)

S. 143(3) :Assessment-limited scrutiny-Disallowance of expenditure-Exempt income-Suo moto disallowed the expenditure-Not part of reasons for limited scrutiny-Capital gains-Short term loss-Suo moto disallowed the expenditure-Disallowance made by the Assessing Officer is deleted. [S. 14A, 28(i), 45, 143(3), R. 8D]

Dahila Infrastructure (P.) Ltd. v. DCIT (2025) 212 ITD 184 (Delhi) (Trib.)

S. 143(3): Assessment-Non existing company-Merger-Assessment was invalid and quashed. [S. 170]

Liquidhub Analytics (P.) Ltd. v. NFAC (2025) 212 ITD 349 (Pune) (Trib.)