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 ITAT Ahmedabad held that isolated WhatsApp messages and electronic communications cannot, by themselves, support additions in ...
Income Tax : ITAT Ahmedabad held that penalty under Section 43 of the Black Money Act could not be imposed when foreign assets were subsequentl...
Income Tax : The Hyderabad Bench emphasized that penalty under Section 271(1)(c) cannot be imposed solely because an addition survives appellat...
Income Tax : The Tribunal held that Section 263 cannot be invoked where the assessee never claimed the alleged expenditure as a deduction. With...
Income Tax : The Tribunal ruled that proportionate interest disallowance under Section 36(1)(iii) cannot be sustained when the assessee has ade...
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 Tribunal held that deduction under section 80-IA cannot be allowed mechanically based on past relief. Each infrastructure project must be independently examined to determine whether it qualifies as development or is merely a works contract.
The Tribunal reaffirmed that satisfaction must be recorded contemporaneously or immediately after the searched person’s assessment. Any belated recording invalidates the assumption of jurisdiction under section 153C.
The Tribunal ruled that after primary evidence is furnished, the assessee is not required to prove the source of source under section 68, especially where the AO fails to conduct enquiry u/s 131 or 133(6).
The issue was whether unsecured loan additions under section 68 could survive based solely on investigation reports and third-party statements. ITAT held that without independent enquiry and nexus to seized material, such additions are unsustainable.
The ITAT ruled that section 151 approval must strictly correspond to the recorded reasons for reopening. Any factual inconsistency reflects non-application of mind and collapses the reassessment at inception.
The Tribunal reaffirmed that revision is impermissible when the Assessing Officer adopts a reasonable view after due enquiry. Section 263 cannot be invoked merely because the PCIT prefers another line of investigation.
The Tribunal reaffirmed that once expenditure is shown to be wholly and exclusively for business, section 37(1) disallowance cannot survive. Suspicion cannot override documentary and commercial reality.
The Tribunal held that when purchases are conclusively proved to be sham accommodation entries, the entire amount is disallowable under section 69C. Mere invoices and bank payments cannot override incriminating search evidence and admissions.
The Court held that reassessment notices failed because seized documents did not relate to the relevant assessment years. Jurisdiction under Section 153C was therefore not validly assumed.
Whether additions under sections 68 and 69C can be made without seized material. In search cases, completed assessments cannot be disturbed unless incriminating material is found during the search.
