Income Tax : Smt. Ranjana Kumari/Kalta Vs DCIT/ACIT (Central) (ITAT Chandigarh) The appeals involved three assessees belonging to the Kalta Gro...
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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 : ITAT Delhi held legal services are not FTS under Section 9(1)(vii) and directed partner-wise DTAA examination. FTS addition was de...
Income Tax : ITAT Mumbai deleted a Section 69 addition after finding documentary evidence established joint ownership, source of funds, and ear...
Income Tax : ITAT Mumbai quashed reassessment after finding no Section 143(2) notice and that the AO issued a final order disguised as a draft ...
Income Tax : ITAT Surat held that delayed filing of Form 10B is a procedural lapse and remanded the matter after directing the AO to consider t...
Income Tax : Instruction No.1/2015 Clarification regarding applicability of section 143(1D) of the Income-tax Act, 1961- Vide Finance Act, 2012...
The Tribunal emphasized that assumptions based on common names cannot justify major tax additions. Without documentary linkage or banking trail confirmation, the Revenue’s case could not stand.
The case involved alleged bogus job-work transactions linked to a third party. The Tribunal found the receipts were genuine business income duly audited and taxed, leading to deletion of additions.
The Tribunal ruled that Section 263 cannot be invoked merely because the Commissioner holds a different opinion. Once adequate inquiry is conducted and a reasonable view is taken, revision is unsustainable.
ITAT held that entire purchases cannot be disallowed when sales and stock are accepted. The addition was rightly restricted to 25% to cover possible inflation.
The Tribunal ruled that reopening based merely on audit objection without independent application of mind is unsustainable. An audit note cannot replace the Assessing Officers reasoned belief.
The Tribunal emphasized that without physical goods, exports and stock reconciliation would not be possible. Since quantitative records and gross profit remained consistent, the addition under Section 69C was deleted.
The Tribunal ruled that adopting stamp duty value without obtaining a DVO report violates Section 50C when the assessee disputes fair market value. The matter was restored for fresh adjudication after obtaining proper valuation.
Penalty imposed under Section 271AAA was set aside, holding that only the Assessing Officer is empowered to levy such penalty. The Tribunal further ruled that once quantum addition is deleted, penalty cannot survive.
The Bombay High Court held that a pending penalty appeal qualifies as a “dispute” under the Vivad Se Vishwas Scheme. Rejection solely for absence of assessment appeal was set aside
The Tribunal held that long-term capital gains could not be treated as bogus where documentary evidence supported the transactions and no material connected the assessee to price manipulation. The Revenue’s appeal was dismissed.
