"Experience in direct tax litigation (Appearing before ITAT, CIT(A) and DRP) | Income Tax Assessment & Appeals | Tax Compliance & Advisory | Transfer Pricing Disputes | Tax Planning & Structuring | Legal Research & Drafting | Corporate Taxation | Cross-Border Taxation | Litigation Strategy "
The tribunal held that addition under Section 69C is not valid where expenditure is properly recorded and the source is explained. The key takeaway is that documented transactions through banking channels cannot be treated as unexplained.
ITAT rules that assessments under section 144 without proper section 148 notice are void when returns are filed late, affirming taxpayer procedural rights.
Allahabad High Court held that a Section 148 notice sent via speed post is invalid. Only registered post or proper affixture ensures valid service for reassessment proceedings.
ITAT held that provisions taxing difference in stamp value and purchase price apply only to land and buildings, not leasehold rights. Addition of ₹21.95 lakh was set aside.
Examine the legal disputes surrounding Section 153D approvals for tax assessments, including court rulings on mechanical approvals and their impact.
ITAT Delhi rules an income tax assessment is invalid if the Section 143(2) notice was not issued in the CBDT’s mandatory revised format. This jurisdictional defect voids the entire assessment proceeding.
