Income Tax : The article explains remedies available after adverse tax orders under scrutiny and reassessment. The key takeaway is that choosin...
Income Tax : The Court clarified that mere pendency of information exchange requests under DTAA cannot justify continuing a Look Out Circular. ...
Income Tax : A surge in Section 143(2) notices was triggered by the June 2025 limitation deadline. This explains why cases were picked and how ...
Income Tax : The Tribunal ruled that penalty under Section 271A cannot be levied merely because books were rejected and income was estimated. S...
Income Tax : The ITAT held that an assessment completed before receiving the DVO report under section 50C(2) is invalid. All additions and disa...
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 : Tribunal observed that the Assessing Officer failed to establish any mismatch in stock, sales, or accounting records before making...
Income Tax : ITAT Hyderabad held that constituent members of a JV or Consortium can claim deduction under Section 80IA(4) when they actually ex...
Income Tax : The Tribunal found that full payment, TDS deduction, and transfer of possession established completion of the transaction for capi...
Income Tax : ITAT Rajkot held that cash deposits made during demonetization were fully supported by audited books of account, cash books, and b...
Income Tax : The Hyderabad ITAT held that purchases cannot be treated as bogus merely because the supplier failed to respond to a notice under ...
Income Tax : Instruction No.1/2015 Clarification regarding applicability of section 143(1D) of the Income-tax Act, 1961- Vide Finance Act, 2012...
The AO recorded reasons for escapement without receiving confirmation from the Sub-Registrar. ITAT ruled that absence of tangible evidence vitiated reassessment, making the subsequent Section 263 revision unsustainable.
The ruling emphasized that tax authorities must gather evidence instead of relying on coerced admissions. Additions made purely on surrender statements were struck down for violating CBDT guidelines.
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.
