Denial of deduction u/s. 80-G/80-GGA r.w.s. 35AC in respect of donations made to eligible Trust/Institutions - assessee carried the issue in second appeal before the Tribunal HELD THAT:- The appeal was dismissed as infructuous, since the same deduction relief had already been granted in the assessee's earlier appeal for the same assessment year [2022 (7) TMI 392 - ITAT DELHI] following the decision rendered in the case of Bhoopati Shikshan Pratisthan [2022 (2) TMI 694 - ITAT MUMBAI].... ... ...

Unexplained money - cash found during search recorded in cash book - Unexplained expenditure - loose-paper entries recorded in cash book Unexplained money - cash found during search recorded in cash book - Addition for cash found at the assessee's residential premises - whether it could be treated as unexplained money when reflected in the cash book? - HELD THAT: - An addition for unexplained money can be made only where the cash is not recorded in the books of account. The cash balance w... ... ...

Constitutional immunity of income of a State instrumentality -Taxability of interest/income earned on FDRs/conversion charges by an Instrumentality of the State and/or Department/Organization of the State - Urban Improvement Trust as instrumentality of State Article 289 immunity - State instrumentality - Taxability of the income of the statutory Urban Improvement Trust as income of a State instrumentality under Article 289(1) of the Constitution - HELD THAT: - Article 289(1) exempts the prope... ... ...

Revision u/s 263 - plausible view on section 80G deduction for CSR expenditure HELD THAT: - Divergent Tribunal views existed on the allowability of deduction under section 80G for CSR expenditure. Since the Assessing Officer had adopted one plausible view, the assessment order could not be regarded as both erroneous and prejudicial to the interests of the Revenue merely because the Principal Commissioner preferred the contrary view. Revision under section 263 is unavailable where two reasonab... ... ...

Addition for cash deposits in a joint bank account - Failure to consider documentary evidence - supporting bank statements and sale documentation relevancy - HELD THAT: - The appellate authority rejected the explanation for want of supporting evidence, although the assessee had furnished documentary material, including bank statements and sale documentation. As the material required factual verification by the Assessing Officer and the assessment had been completed without securing the assessee&... ... ...

Assessment u/s 153A - completed assessments and incriminating material - Deduction for power-generation business-alleged breach of section 47(xiii) Assessment u/s 153A - Validity of the disallowance of the deduction claimed by the power-generation business in a non-abated assessment u/s 153A on the basis of the seized documents - HELD THAT: - The earlier Tribunal order [2024 (11) TMI 1367 - ITAT BANGALORE] concerning the same search material had held that the documents were not incriminating ... ... ...

Addition based on Search statements - corroboration for cash-purchase additions - Unsigned loose sheets-evidentiary value for undisclosed income - Accrual of interest income Addition for alleged non-genuine cash purchases of maize based on search and post-search statements and self-made vouchers recorded in the regular books - HELD THAT: - A statement recorded on oath has evidentiary value but is not conclusive and cannot, by itself, sustain an addition unless supported by incriminating mater... ... ...

Unexplained money u/s 69A - cash deposited during the demonetisation period - Specified bank notes - explained business receipts HELD THAT: - The cash book, audited accounts and material filed during assessment showed the recorded cash balance and the asserted sources of deposits. The commercial practice of advances to paddy-procurement agents and their return upon demonetisation was corroborated by sworn evidence; although agents were available, only one was examined, and no material was bro... ... ...

Approval u/s 80G for educational grants - Application of charitable income in India - trust providing educational grants in India to Indian students pursuing studies abroad HELD THAT: - Approval under section 80G requires satisfaction regarding the genuineness of the trust's activities and fulfilment of the prescribed conditions; no adverse finding was recorded on the genuineness of activities. The object clause contemplated financial assistance for studies in India or abroad, while the t... ... ...

Revisionary jurisdiction u/s 263 - Deduction u/s 80G for corporate social responsibility donations Revisionary jurisdiction - order erroneous and prejudicial assessment - Change of opinion - Validity of revision of an assessment allowing deduction u/s 80G for corporate social responsibility donations after inquiry by the AO - HELD THAT: - The assessee had disclosed the CSR-related donations and furnished the particulars sought in scrutiny. Though the assessment order did not specifically disc... ... ...

Nature of expenditure - Capital or revenue character of mining-lease renewal payment - Substance over form - Depreciation on mining licence as intangible asset Stamp duty for renewal of mining lease - capital or revenue expenditure - Substance over form - Deductibility of stamp duty paid for renewal of a mining lease conferring a right to win iron ore minerals for a renewed term - HELD THAT: - The renewed mining lease conferred a transferable right to undertake mining operations and win miner... ... ...

Validity of assessments u/s 153C - satisfaction for search - statutory expressions "belong to or belong to" or "pertain to or pertains to" or "relate to or relates to" Validity of search-related assessments where the satisfaction recorded by the Assessing Officer of the searched party did not identify whether the seized material belonged to, pertained to, or related to the assessee - HELD THAT: - A valid satisfaction under section 153C requires the statutory nexus between the seized material ... ... ...

Search assessment u/s 153C - year-specific satisfaction note - Incriminating material - regular ledger entries Validity of an assessment under section 153C founded on a consolidated satisfaction note for multiple assessment years, where the alleged incriminating material was only a ledger account - HELD THAT: - A satisfaction note is required to be recorded separately for each assessment year. A consolidated note, without identifying how a regular ledger account constitutes incriminating mate... ... ...

Judicial discipline pending consideration of identical issue by Supreme Court - Stay of proceedings to avoid multiplicity of litigation Adjudication of challenge to a notice issued under section 148 where the legality of the impugned notice was already pending before the Supreme Court - HELD THAT: - As the issue raised was pending consideration before the Supreme Court [2024 (5) TMI 1577 - SC ORDER], judicial discipline required the Court to refrain from expressing any opinion on the validity... ... ...

Consensual remand for merits adjudication - Consensual remand of the income-tax matters for adjudication on merits without considering the technical objection concerning Document Identification Number (DIN) HELD THAT: - As both sides consented to a remand and the Tribunal had pronounced only on the technical aspect, the matters required adjudication on their merits. [Paras 4] The matters were remanded to the ITAT Panaji Bench for merits adjudication, without looking into the technical obje... ... ...

Typographical errors have crept up or certain omissions are noticed - On Page 1 in the cause title of the order dated 25.09.2026, "Tax Appeal No. 20/2024" shall be read as "Tax Appeal No. 24/2024" and on page 4 in the cause title "Tax Appeal No. 23/2024" shall be added before Cross-Objection No. 3055/2024(F). Accordingly, necessary corrections be carried out, and the corrected copy to be uploaded on the website.... ... ...

GST authorities issued Show Cause Notices post the search which was undertaken by the DGGI along with the officials of the Directorate of Revenue Intelligence - Whether DGGI show-cause notice may proceed despite earlier State GST notices concerning common parties and transactions? HELD THAT:- Pending consideration of the writ petition, the respondents were restrained from taking further steps pursuant to the impugned show cause notice, without prejudice to the DGGI transmitting material to th... ... ...

GST reimbursement and differential tax on works contracts - Entitlement of a public-works contractor to reimbursement of GST and differential tax, with consequential validity of the demand for tax, interest and penalty HELD THAT: - The Court held that the controversy stood answered by its earlier decisions Shri. M.G. Arunkumar [2023 (8) TMI 1531 - KARNATAKA HIGH COURT] and Sri. Chandrashekaraiah and others [2023 (6) TMI 93 - KARNATAKA HIGH COURT] governing the GST consequences of public works... ... ...

Refund of Kerala Flood Cess paid under incorrect account - Relevant date for refund limitation Determination of relevant date for limitation of a refund claim for Kerala Flood Cess mistakenly paid through GSTR Form-1 instead of the prescribed account - HELD THAT: - Though the provisions concerning tax paid under an incorrect head were not strictly applicable to Kerala Flood Cess, the principles in the Circular's illustration were applicable by analogy. Right to seek refund arose only upon... ... ...

Customs enforcement at Bengaluru airport involved interception and arrest of passengers allegedly attempting to smuggle hydroponic ganja and gold by concealing the goods in cabin baggage, other baggage, undergarments, or on the body. Cases involved arrivals from Vietnam, Bangkok, Kuala Lumpur, and Abu Dhabi. The Abu Dhabi gold-ornament case involved an arrest under the Customs Act.