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 Tribunal clarified that approval under section 153D is an administrative safeguard and need not contain elaborate reasoning. Allegations of mechanical approval fail without concrete evidence of non-application of mind.
The ruling clarifies that unsecured loans taken and repaid during the same year through banking channels cannot be treated as unexplained credits. Proper documentation and repayment negate allegations of bogus loans
The Tribunal held that additions in a search assessment cannot survive without incriminating material. Mere repetition of an annulled earlier assessment was found legally unsustainable.
The decision reiterates that the Revenue must prove that borrowed funds were actually used for non-business purposes. In absence of such proof, interest paid to banks remains allowable.
It was ruled that once books are accepted, expenses supported by ledgers, vouchers, and bank payments cannot be disallowed on suspicion. Ad-hoc estimation without rejecting books was held invalid.
The ruling explains the procedural outcome when a section 263 order is set aside. Original assessment appeals are restored, while appeals from consequential orders are dismissed as infructuous.
The tribunal held that reliance on an investigation report cannot override the statutory requirement of section 68. Where the assessee maintained no books, additions based solely on bank credits were invalid.
The ruling clarifies that penalty cannot be levied merely because expenses are partly disallowed on estimation. Absence of under-reporting or misreporting defeats the penalty action.
Upholding the appellate order, the Tribunal ruled that section 68 applies only to credits of the relevant year. Opening balances and prior period adjustments cannot be taxed as unexplained income in a subsequent year.
The issue concerned valuation of royalty for bundled services. ITAT held that faulty comparables vitiated the CUP analysis and ordered fresh benchmarking.
