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...
Delhi ITAT held that adding hypothetical interest on security deposits to compute ALV is impermissible. The decision reverses lower authorities, confirming that only real contractual rent counts as income under section 23(1).
The Court ruled that services rendered remotely cannot create a PE because the treaty requires services furnished within India through employees. virtual presence cannot substitute physical presence without treaty amendment.
Tribunal held that a provision for bad debts need not be routed through the Profit & Loss account in the first eligible year under Section 36(1)(viia). The disallowance was deleted as the audited statements reflected the provision as on 31.03.2007.
Applying the Supreme Court’s principle, the Tribunal held that an explanation unproved but not disproved cannot attract Section 271(1)(c) penalty. It noted that the department failed to show falsity in the assessee’s claims. The takeaway is that penalty requires clear evidence of incorrect particulars, not mere inadequacy of proof.
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.
ITAT Chennai quashed reassessment under Section 147, ruling that reopening based on a change of opinion without new material is invalid.
The Hyderabad tribunal clarified that section 144C provisions are procedural and cannot extend the statutory limitation under section 153. The AO passed the final assessment order after the permissible period, leading to quashing. The ruling strengthens the principle that statutory deadlines are paramount in tax proceedings.
The Telangana High Court held that a Section 148 notice issued for AY 2017-18 was invalid and barred by the six-year limitation under the first proviso to Section 149. Reopening assessments beyond the prescribed period is impermissible.
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.
