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...
Cane Deveopment Council Rohana Kalan Vs ITO (ITAT Delhi) The appeals concern penalties imposed under Section 271(1)(c) of the Income Tax Act for Assessment Years 2010–11 and 2011–12. Four appeals filed by two assessees were heard together due to similarity in facts, with one matter treated as the lead case. The assessee challenged the penalty […]
ITAT Jaipur held that the amount paid before due date of filing the return of income is not supposed to be disallowed under section 43B of the Income Tax Act even though the same was outstanding at the year. Accordingly, AO directed to verify the said aspect and pass appropriate order.
ITAT Pune deletes Rs.17.90L addition u/s 68 as LLP proved genuineness, identity & repayment of unsecured loans; appeal allowed in full.
Additions based on decoded entries from a third-party cash book were struck down, as they did not align with the assessee’s audited books or bank statements, reinforcing the ‘dumb document’ principle.
The ITAT held that a penalty under section 271(1)(c) cannot survive once the underlying quantum addition is deleted by a binding ITAT order. The Revenue’s appeal was dismissed as no stay or direction from the High Court could revive the deleted quantum.
The Court held that Section 270A cannot be invoked when assessed income matches the returned income, and an excessive FTC claim alone does not constitute under-reporting. Key takeaway: Penalty requires statutory pre-conditions to be satisfied, not mere disagreement on a claim.
Tribunal holds that working capital impact must be examined by the TPO when comparables are selected by the Department. If adjustment is granted, no separate interest addition is warranted.
The Tribunal ruled that interest could not be disallowed when ample interest-free funds existed and no link was shown between overdraft borrowings and partners’ drawings. The key takeaway is that presumption of utilisation of own funds applies when mixed funds are available.
The Tribunal held that reassessment could not stand because the recorded reasons pertained to a different assessment year. The reopening was invalid, and all related additions were rendered infructuous.
The Tribunal agreed with the CIT(A) that penalty cannot continue after the underlying addition ceases to exist. The ruling highlights strict adherence to the principle of dependency between quantum and penalty.
