Delhi ITAT Says Entire Bogus Purchase Value Can't Be Added To Income, Applies 5% Rate On ₹5.94 Cr Turnover

The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) on 31 August held that where both purchases and corresponding sales are found to be bogus, the entire purchase value cannot be added to income without accounting for the profit element arising from the transactions. Judicial Member Anubhav Sharma and Accountant Member Sanjay Awasthi partly allowed HSB Home Solutions Ltd.'s appeal for Assessment Year 2012-13, upholding the reopening of the assessment and directing the Assessing Officer...

ITAT Delhi Quashes Revision Against Sr. Advocate Mukul Rohatgi For CCIT's Unauthorised PCIT Notice

The Delhi Income Tax Appellate Tribunal (ITAT) on 28 August quashed the revisionary order passed against Senior Advocate Mukul Rohatgi for Assessment Year 2022-23, holding that the Section 263 notice issued by the officer after his promotion to CCIT was without jurisdiction.A Bench comprising Vice President Mahavir Singh and Accountant Member Sanjay Awasthi held that an officer promoted as Chief Commissioner of Income Tax (CCIT) cannot exercise the powers of the Principal Commissioner of...

Assessment Years Falling Beyond Prescribed Period Cannot Be Reopened In Search Proceedings: ITAT Delhi

The Delhi Income Tax Appellate Tribunal (ITAT) on 24 August held that an Assessing Officer cannot assume jurisdiction under Section 153C of the Income Tax Act, 1961, for assessment years falling outside the statutory block prescribed under the provision. The provision applies to the assessment of income of a person other than the person searched, where seized material is found to relate to such person.A Bench comprising Accountant Member S. Rifaur Rahman and Judicial Member Sunil Kumar Singh...

ITAT New Delhi Quashes Reassessment Based On Information Already Available On Record

The Delhi Income Tax Appellate Tribunal (ITAT) on 24 August 2026 held that reassessment proceedings cannot be initiated by presenting information already available on the assessment record as fresh material. Such proceedings are without jurisdiction. A Bench comprising Accountant Member S. Rifaur Rahman and Judicial Member Sunil Kumar Singh allowed five connected appeals involving Jay Ace Technologies Limited, JNJ Electronics Limited and other companies of the JP Minda Group for Assessment Year...

Bombay High Court Quashes Reassessment Against Royal Chains, Says 'Reason To Suspect' Not Enough

The Bombay High Court on 24 August quashed an Income Tax reassessment notice issued to jewellery manufacturer Royal Chains Pvt Ltd for Assessment Year 2016-17. A Division Bench of Justices B.P. Colabawalla and Farhan P. Dubash noted that a completed Income Tax assessment cannot be reopened merely on the basis of suspicion about an investor's background, without material having a direct nexus with the particular transaction and the alleged escapement of income. It observed: “The connection that...

Supreme Court Refuses To Interfere With Delhi HC Ruling On GoDaddy Domain Fees Under India-US DTAA

The Supreme Court on Monday refused to interfere with the Delhi High Court order holding that payments received by GoDaddy.com LLC from Indian customers towards domain-name registration services are not chargeable to income tax in India under the India-US Double Taxation Avoidance Agreement (DTAA). A Bench of Justices K.V. Viswanathan and Arun Palli after hearing the parties, refused to interfere with the Delhi High Court's order. The Supreme Court was hearing the Income Tax...

Chhattisgarh HC Upholds ₹37.74L Compensation To Accident Victim's Mother, Says No Tax Deduction Below ₹5L

The Chhattisgarh High Court on 20 August held that income tax need not be deducted while calculating motor accident compensation if the deceased's income falls within the Rs. 5 lakh limit eligible for rebate under Section 87A of the Income Tax Act. Justice Sanjay Kumar Jaiswal upheld the Motor Accident Claims Tribunal's decision not to deduct tax from the deceased's annual income of Rs. 4,34,970, including 50% towards future prospects, and dismissed his mother's appeal seeking enhancement of...

Delhi ITAT Excludes 4 Companies From WNS Transfer Pricing Comparables, Says Functional Similarity Is Key

The Delhi Income Tax Appellate Tribunal (ITAT) on 25 August upheld the exclusion of Eclerx Services, TCS E Serve, Infosys BPO and Acropetal Technologies from WNS Business Consulting Services' comparable set, observing that transfer-pricing comparables must be assessed on their actual functional profile rather than merely on their presence in the same broad industry. A Bench comprising Judicial Member Satbeer Singh Godara and Accountant Member Manish Agarwal dismissed the Revenue's appeal for...

Delhi ITAT Deletes ₹168.31 Cr Addition Against Hero FinCorp, Says DCF Valuation Must Use Available Facts

The Delhi Income Tax Appellate Tribunal (ITAT) on 25 August deleted a Rs. 168.31 crore share premium addition made against Hero FinCorp for Assessment Year 2018-19 under Section 56(2)(viib) of the Income Tax Act, 1961. Accountant Member S. Rifaur Rahman and Judicial Member Raj Kumar Chauhan held that the company's Discounted Cash Flow (DCF) projections could not be rejected merely by comparing them with subsequent financial results, and allowed the company's appeal. The Bench observed: “These...

Calcutta High Court Upholds Reassessment Against Chirania Projects, Orders Personal Hearing

The Calcutta High Court on 18 August upheld reassessment proceedings initiated against Chirania Projects Private Limited for Assessment Year (AY) 2019-20, while directing the Assessing Officer to provide the company an opportunity of personal hearing during the reassessment. Justice Smita Das De passed the order while hearing the company's writ petition challenging the 30 June 2025 order under Section 148A(3) of the Income Tax Act and the consequential notice under Section 148. She observed: ...

Interest On Trust's FDs Taxable Without Specific Donor Direction For Corpus: Madras High Court

The Madras High Court on 17 August held that interest earned on fixed deposits maintained by a Trust is taxable revenue receipt where donors have not specifically directed that such interest form part of the Trust's corpus. A Bench comprising Chief Justice Sushrut Arvind Dharmadhikari and Justice G. Arul Murugan dismissed an appeal filed by St. Joseph's Development Trust, upholding the addition of Rs. 94.66 lakh as taxable interest income for Assessment Year (AY) 2017-18. The judges held: ...

Supreme Court Directs Union To Consider 60-Day Tax Relief For Seafarers Stranded In India During COVID-19

The Supreme Court on 21 August directed the Union of India to sympathetically consider representations filed by Merchant Navy Officers and Ladies Association (MNOLA) seeking a 60-day tax exemption for Indian seafarers who remained in India for more than 182 days during the COVID-19 pandemic. A Bench comprising Chief Justice Surya Kant with Justices Joymalya Bagchi and V. Mohana disposed of the writ petition without expressing any opinion on merits and directed the Union to take an appropriate...