Income Tax : The ruling clarifies that unauthenticated digital chats and screenshots cannot form the sole basis of tax additions without proper...
Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...
Income Tax : Section 270A penalties must specify the exact misreporting clause. Vague notices invalidate penalties and can restore immunity und...
Income Tax : Understand the three core processes of Indian Income Tax: Rectification of mistakes (Sec 154), the four types of Assessment (Summa...
Income Tax : Understand your legal rights and procedural protections during Income Tax and PMLA raids in India. Learn what to do and what to a...
CA, CS, CMA : Legal opinion sought by NFRA on auditing standards, penalties, and regulatory roles in India. Analysis of NFRA’s powers under th...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Goods and Services Tax : The Ministry of Finance reports the arrest of a firm's finance head for GST evasion worth Rs 88 crore. Learn about the case and it...
Income Tax : The Central Board of Direct Taxes ( CBDT) has directed re-opening of all cases under the search and seizure label, income-escapin...
Income Tax : The case examined whether compensation paid to exit prior agreements was a sham arrangement. The Tribunal ruled it was a valid bus...
Income Tax : The Tribunal held that an unsigned agreement without corroboration cannot be treated as incriminating material. Proceedings under ...
Income Tax : The Tribunal deleted additions where the Revenue failed to prove actual cash transactions. It emphasized that suspicion and assump...
Income Tax : The Tribunal held that loan repayment cannot be treated as unexplained cash credit under section 68. The addition was deleted as i...
Income Tax : Reassessment proceedings was invalid for a notice issued beyond three years without the sanction of the prescribed higher authorit...
Income Tax : Read the order issued by the Central Board of Direct Taxes (CBDT), Ministry of Finance, specifying the scope of the e-Appeals Sche...
Income Tax : Dispute arose between the Department and the assessees with regard to adjustment of such seized/requisitioned cash against advance...
The ITAT ruled that section 69A cannot be invoked unless ownership of cash is established. Mere third-party seized ledgers without recovery of money are insufficient to sustain an addition.
The ITAT held that reassessment was invalid where notices and orders showed shifting facts and no independent reasoning. Changing bases across stages reflected a casual approach that vitiated jurisdiction.
The Tribunal examined whether an addition under section 153C could survive without seized material. It held that in an unabated year, additions are impermissible without incriminating evidence found during search, leading to deletion of the addition.
The Tribunal ruled that non-filing of returns, absence of audited books, and lack of donor details defeat the claim for exemption under Section 13A. Voluntary contributions thus became taxable, though Section 68 additions were set aside.
ITAT Delhi clarified that Section 153A is not meant to reassess completed years in absence of seized evidence. The ₹6.11 lakh addition was therefore held to be without jurisdiction.
While sustaining additions on merits, ITAT Delhi restricted taxable income to a lump-sum 8% of Section 68-type amounts. The estimation was granted as a one-time relief and expressly not treated as a precedent.
The Tribunal reiterated that tax authorities cannot impose notional income merely because interest could have been charged. Commercial decisions on interest-free advances lie with the assessee, not the assessing officer.
The Bombay High Court held that additions under Section 153A cannot be made for completed assessments when no incriminating material is found during search. Post-search documents like base notes are insufficient to justify additions.
Delhi ITAT held that a bank’s valuation report obtained post-search is not incriminating material, restricting unexplained investment addition to a reasonable estimate.
ITAT Hyderabad held that an unsigned sale agreement cannot automatically justify higher capital-gains additions. The AO must verify actual receipt of funds before confirming any addition.
