https://www.taxtmi.com/caselaws?id=784933 ITAT upheld validity of initiation under s.147/notice u/s.148: Range head has concurrent jurisdiction and undated/unsigned reasons were not fatal where accompanying cover letter bore DIN, so the challenge to reopening was dismissed. On deemed dividend u/s.2(22)(e): transactions characterized as ordinary course share-sale/purchase supported by precedent and CBDT Circular, hence addition deleted. On s.14A disallowance: absence of share investments in the proprietor's balance sheet negated allegation of expenses relating to exempt dividend, so disallowance deleted. On short-term capital loss from property sale: lack of cogent evidence of transfer and indicia of device led ITAT to confirm AO's addition. On s.41(1) and s.68 additions: AO's estimates/excessive jurisdiction disapproved and additions deleted. Disallowance of commission and related adjustments remitted to sustain AO's inquiries where statutory notices were not complied with. en-us Fri, 09 Jan 2026 00:00:00 +0530 Wed, 14 Jan 2026 08:56:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784933 ITAT upheld validity of initiation under s.147/notice u/s.148: Range head has concurrent jurisdiction and undated/unsigned reasons were not fatal where accompanying cover letter bore DIN, so the challenge to reopening was dismissed. On deemed dividend u/s.2(22)(e): transactions characterized as ordinary course share-sale/purchase supported by precedent and CBDT Circular, hence addition deleted. On s.14A disallowance: absence of share investments in the proprietor's balance sheet negated allegation of expenses relating to exempt dividend, so disallowance deleted. On short-term capital loss from property sale: lack of cogent evidence of transfer and indicia of device led ITAT to confirm AO's addition. On s.41(1) and s.68 additions: AO's estimates/excessive jurisdiction disapproved and additions deleted. Disallowance of commission and related adjustments remitted to sustain AO's inquiries where statutory notices were not complied with. Case-Laws Income Tax Fri, 09 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784933