Income Tax : Smt. Ranjana Kumari/Kalta Vs DCIT/ACIT (Central) (ITAT Chandigarh) The appeals involved three assessees belonging to the Kalta Gro...
Income Tax : Learn the updated provisions governing rectification, assessments, reassessments, and appeals under the Income-tax Act. This guide...
Income Tax : The article explains how the Finance Acts, 2025 and 2026 have reshaped the Updated Return regime under Section 139(8A). It highlig...
Income Tax : The article explains that 30 June is the Department's deadline to issue scrutiny notices for eligible returns, not a filing deadli...
Income Tax : The Income Tax Department explains how faceless assessments under Section 144B operate through the e-Filing portal without requiri...
Income Tax : Read how Income Tax Gazetted Officers’ Association addresses last-minute case reallocations affecting timely issuance of notices...
Income Tax : The Supreme Court has ruled that it is mandatory for the Income Tax Department to issue notice within the prescribed time limit of...
Income Tax : Where unaccounted sales were established through seized material, only the net profit embedded therein was liable to tax, and not ...
Income Tax : ITAT Bangalore held that additions made in an intimation under Section 143(1) cannot be disputed in an appeal against a scrutiny a...
Income Tax : Interest on delayed payment of the FM radio migration fee was a compensatory business expenditure deductible under Section 37(1); ...
Income Tax : ITAT Mumbai remanded the case to examine whether Section 56(2)(x) applied based on the agreement date and to consider refund of ex...
Income Tax : ITAT Mumbai deleted a Section 69 addition after finding documentary evidence established joint ownership, source of funds, and ear...
Income Tax : Understand the guidelines set by the Indian Ministry of Finance for the compulsory selection of returns for complete scrutiny duri...
Income Tax : CBDT hereby authorises the Assistant Commissioner of Income-tax/Deputy Commissioner of Income-tax (NaFAC) having her / his headqua...
Income Tax : The three formats of notice(s) are: Limited Scrutiny (Computer Aided Scrutiny Selection}, Complete Scrutiny (Computer Aided Scruti...
Income Tax : Central Board of Direct Taxes, with approval of the Revenue Secretary, has decided to modify notice under section 143(2) of the In...
Income Tax : Instruction No.1/2015 Clarification regarding applicability of section 143(1D) of the Income-tax Act, 1961- Vide Finance Act, 2012...
The Revenue relied on third-party statements and WhatsApp data to allege an unrecorded ₹25 crore cash loan, but brought no supporting inquiry or cross-examination. The Tribunal held that the AO’s conclusion was speculative, especially when bank-backed evidence, TDS records, and a registered loan agreement supported only a ₹10 crore loan. Key takeaway: additions under Section 69A require concrete evidence, not assumptions.
The Tribunal directed fresh examination of whether the government allocation received by the assessee constituted a corpus fund under section 11(1)(d). It held that the lower authorities had not properly considered the assessee’s submissions, requiring the matter to be verified afresh.
The ITAT Pune held that splitting royalties for domestic vs export sales was impermissible, deleting the entire transfer pricing adjustment. The ruling reinforces that TNMM aggregation for manufacturing includes royalties as a single element.
The Tribunal held that even extraordinary circumstances like COVID-19 do not justify appeals filed after limitation expiry. The assessee’s appeal was dismissed due to failure to provide cogent reasons or affidavits supporting the delay.
ITAT Pune ruled that income from temporarily letting sugar factory assets is business income, not Income from Other Sources, allowing set-off of brought-forward losses.
The ITAT Hyderabad held that a notice issued by the Jurisdictional AO under Sections 148A(b) and 148 after the Faceless Jurisdiction Scheme, 2022, is without jurisdiction and void. The reassessment order based on such notice was consequently quashed. This ruling reinforces the mandatory requirement for faceless reassessment under the 2022 scheme.
The Tribunal ruled that the seized notes clearly connected the assessee to both the loan and property investment, validating jurisdiction under Section 153C. The assessee’s failure to submit any proof led to confirmation of the additions. The case highlights the importance of evidence-based rebuttal in search-related assessments.
The Tribunal upheld the rejection of unreliable books but ruled that the AO could not estimate net profit at 12% without justification, vacating ₹65.08 lakh addition.
ITAT restored Rs. 20 Cr in unsecured loans, interest, and squared-up loans for fresh verification, noting CIT(A) erred by deleting additions at the stroke of a pen. Large new loans and substantial repayments required independent checks on purpose and creditworthiness. The ruling reinforces that appellate deletion without inquiry violates Rule 46A and legal principles under sections 68 and 69.
The Tribunal ruled that the AO erred in applying a 15% illiquidity discount on shares valued by the NAV method. SEBI MF guidelines and DCF-based precedents were deemed irrelevant. The assessee’s valuation was confirmed, and the Rs. 8.70 crore addition was nullified.
