Income Tax : Smt. Ranjana Kumari/Kalta Vs DCIT/ACIT (Central) (ITAT Chandigarh) The appeals involved three assessees belonging to the Kalta Gro...
Income Tax : Understand the statutory time limits for issuing income-tax notices and completing assessments under the Income-tax Act. The guide...
Income Tax : Learn the updated provisions governing rectification, assessments, reassessments, and appeals under the Income-tax Act. This guide...
Income Tax : Learn how different types of income tax assessments are conducted under the Income-tax Act. The FAQs explain assessment procedures...
Income Tax : Section 154 permits rectification of mistakes apparent from the record in assessment orders, intimations, and TDS/TCS processing s...
Income Tax : Delhi ITAT allows Sanco Holding, a Norwegian company, to compute income from bareboat charter of seismic vessels under Article 21(...
Income Tax : It has been observed that in many cases an assessee may wish to make a claim which was not made in the return of income filed unde...
Income Tax : We have attached a file in excel format. The file contains the format of various details which normally assessing officer asks As...
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 issue was whether a final assessment under the DRP framework can be passed beyond statutory timelines. The Tribunal held that orders exceeding Section 153 limits are void, reaffirming strict adherence to limitation.
The dispute concerned whether transfer through a release deed amounted to a taxable sale and justified loss claims. The Tribunal remanded the matter, directing verification of books to examine the genuineness of the claimed loss.
The issue was whether revision under section 263 could be invoked when the Assessing Officer had accepted a legally possible view. The Tribunal held that where two views exist and the AO adopts one, the order is neither erroneous nor prejudicial.
The decision clarifies that voluntary admission and taxation of income post-search does not ipso facto warrant penalty. Absence of contumacious conduct weighed against the Revenue.
The Assessing Officer inferred undisclosed loans by applying a notional interest rate to declared interest income. The Tribunal ruled that additions under section 69B cannot rest on assumptions ignoring the business model.
Failure to comply with section 143(2) by the competent Assessing Officer invalidates the assessment. The decision underscores strict adherence to jurisdictional requirements under the Act.
The tribunal examined whether a Singapore entity could claim DTAA exemption on capital gains from sale of Indian shares. It held that treaty benefits were unavailable as the entity lacked commercial substance and functioned as a shell or conduit.
The decision reiterates that reassessment cannot be initiated on borrowed satisfaction or presumptions. Independent application of mind by the Assessing Officer is mandatory for a valid reopening.
The Tribunal held that reassessment initiated solely on the basis of an audit objection, without any independent application of mind, is invalid. Such reopening lacks the mandatory reason to believe and cannot sustain in law.
The Tribunal held that revision under section 263 was invalid where the MAT adjustment arose mechanically from a transition amount already examined in an earlier year, and no fresh error was shown.
