Delhi ITAT held that uncorroborated WhatsApp messages and digital chats cannot by themselves establish undisclosed cash transactions. The Tribunal deleted additions made solely on presumptions without independent evidence.
Delhi ITAT held that cash deposits during demonetisation cannot be treated as unexplained when supported by prior bank withdrawals. The Tribunal ruled that the Revenue must prove cash was spent elsewhere before invoking Section 69A.
ITAT Raipur held that penalty proceedings initiated after unreasonable delay violated the statutory limitation prescribed under Section 275(1)(c). The Tribunal ruled that delayed penalty orders cannot survive once limitation expires.
Bombay High Court held that revisionary powers under Section 263 cannot be invoked where the Assessing Officer had already conducted enquiries and accepted a plausible view. Mere dissatisfaction with the depth of enquiry does not render the assessment order erroneous.
ITAT Kolkata held that entire bogus purchases must be added under Section 69C where the supplier was proved to be a paper entity and no evidence of actual delivery of goods existed. The ruling reiterates that bank payments and invoices alone cannot establish genuineness.
ITAT Kolkata held that presumptive taxation under Section 44AD was wrongly invoked where the assessee’s turnover exceeded ₹2 crore. The Tribunal clarified that statutory turnover limits must be strictly satisfied before applying presumptive profit provisions.
The ITAT ruled that penalty proceedings under Section 271D are invalid if the Assessing Officer fails to record satisfaction in assessment or related proceedings. Since no assessment proceedings existed in the case, the penalty was held unsustainable in law.
The ITAT Hyderabad held that additions for alleged cash payments cannot be sustained merely on the basis of third-party seized documents. The Tribunal ruled that absence of corroborative evidence, cash trail, or signed records makes such additions legally unsustainable.
The issue addresses the consolidation of multiple presumptive taxation provisions into a single section. The framework simplifies compliance while retaining key conditions and safeguards for taxpayers.
The case examined validity of a reassessment notice issued beyond statutory limits. The ITAT held the notice invalid as it exceeded the permissible time period. It reinforces strict compliance with limitation provisions.
