Section 69A Addition Cannot Survive Without Proof of Ownership of Unaccounted Cash: Important Tribunal Ruling   In a significant ruling on unexplained money under Section 69A of the Income Tax Act, the Tribunal has held that merely because an assessee is a key decision-maker in a company does not automatically establish personal ownership of unaccounted…

ITAT Mumbai: Business Expenditure Cannot Be Disallowed Merely on Suspicion, Assumptions, or Surmises     In a significant ruling reinforcing the principles of consistency and evidence-based taxation, the Mumbai Bench of the Income Tax Appellate Tribunal (ITAT Mumbai) has held that business expenditure cannot be disallowed merely on doubts, assumptions, or surmises when: •  Supporting…

ITAT Chandigarh Grants Major Relief Under Section 54: Old Construction Cost Cannot Be Rejected Merely for Lack of Old Bills     In a significant ruling on capital gains exemption under Section 54 of the Income Tax Act, the Chandigarh Bench of the Income Tax Appellate Tribunal (ITAT Chandigarh) has held that indexed cost of…

Has the Supreme Court Quietly Diluted the “Change of Opinion” Doctrine? A Critical Look at Sanand Properties Pvt. Ltd. vs. JCIT   The Supreme Court’s recent ruling in Sanand Properties Pvt. Ltd. vs. JCIT [(2026 INSC 472) dated 12.05.2026], authored by Hon’ble Justice J.B. Pardiwala, may prove to be one of the most consequential reassessment judgments delivered…

Penalty Under Section 270A Invalid if AO Fails to Specify Exact Charge: Important ITAT Bangalore Ruling   In a significant ruling on penalty proceedings under Section 270A of the Income Tax Act, the Bangalore Bench of the Income Tax Appellate Tribunal (ITAT Bangalore) has held that penalty proceedings become legally unsustainable where the Assessing Officer…