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    Assessment Framing defect: assessment in name of non existent amalgamating entity is void and not curable under Section 292B.
    Limitation on reopening: retrospective extension barred so pre-2021 time limit controls validity and 2024 notices are time-barred.
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      ITAT upheld depreciation on solar power plants because...

      Solar depreciation, share valuation, TDS on derivatives brokerage and mechanical section 153D approval were decided in favour of taxpayers.

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      Income TaxMarch 28, 2026Case LawsAT
      ITAT upheld depreciation on solar power plants because documentary evidence showed purchase, installation, commissioning, power generation, invoicing and receipt of sale proceeds, and the Revenue failed to discredit that material. It also rejected the section 56(2)(viib) addition, holding that the assessee could adopt the DCF valuation method and that the Assessing Officer could not substitute NAV without identifying concrete defects in the independent valuation report. Brokerage on commodity derivatives was held outside section 194H, so the section 40(a)(ia) disallowance failed. The Tribunal also sustained the section 14A disallowance only up to exempt income, and quashed the section 153D-based assessment as void because the common approval was mechanical.

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      ActsIncome Tax