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 tribunal held that cash deposits during demonetisation cannot be treated as unexplained income when supported by audited books and stock records. Mere suspicion or surrounding circumstances cannot override accepted accounts.
A single approval was granted for multiple years without examining seized material or draft orders. The Tribunal ruled that such omnibus approval vitiates proceedings under Sections 153A/143(3).
The tribunal held that merely declaring a low net profit rate cannot justify reopening under Section 147. A valid reassessment requires tangible material and a live nexus with income escapement.
The tribunal held that recomputation of deductions under Sections 36(1)(viia)(c) and 36(1)(viii) involves a debatable legal issue. Such matters cannot be corrected through Section 154 rectification proceedings.
The Tribunal held that reopening AY 2012–13 after a post-2021 search was barred by limitation. Applying Supreme Court guidance, it ruled that older limitation periods protect concluded assessments from retrospective reopening.
Since the mandatory notice was issued by an officer lacking jurisdiction, the assessment was quashed as void ab initio. A valid notice by the correct officer within limitation is indispensable.
The tribunal ruled that reassessment beyond four years is barred when reasons do not allege failure to disclose material facts. Mere suspicion of escaped income is insufficient to override the statutory limitation.
Assessees were qualified as companies owning an industrial undertaking within the meaning of Section 72A. Accordingly, the carry forward and set-off of accumulated business losses and unabsorbed depreciation of the amalgamating transport corporations was allowable.
The ITAT held that unsupported DCF valuation could not justify high share premium. The addition under Section 56(2)(viib) was restored after setting aside the appellate relief.
The ITAT held that reopening an assessment after four years without any new tangible material is invalid. A reassessment based merely on re-examining earlier facts was struck down as a change of opinion.
