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 refused to send the matter back for valuation after finding a clear statutory breach. The addition was deleted outright, reinforcing strict compliance with valuation provisions.
The Tribunal upheld deletion of unsecured loan additions after finding that the lenders identity, bank trail, and reserves were established. Low declared income alone was held insufficient to treat the credits as unexplained.
The issue was whether a final assessment under the DRP framework can be passed beyond statutory timelines. The Tribunal held that orders exceeding Section 153 limits are void, reaffirming strict adherence to limitation.
The dispute concerned whether transfer through a release deed amounted to a taxable sale and justified loss claims. The Tribunal remanded the matter, directing verification of books to examine the genuineness of the claimed loss.
The issue was whether revision under section 263 could be invoked when the Assessing Officer had accepted a legally possible view. The Tribunal held that where two views exist and the AO adopts one, the order is neither erroneous nor prejudicial.
The decision clarifies that voluntary admission and taxation of income post-search does not ipso facto warrant penalty. Absence of contumacious conduct weighed against the Revenue.
The Assessing Officer inferred undisclosed loans by applying a notional interest rate to declared interest income. The Tribunal ruled that additions under section 69B cannot rest on assumptions ignoring the business model.
Failure to comply with section 143(2) by the competent Assessing Officer invalidates the assessment. The decision underscores strict adherence to jurisdictional requirements under the Act.
The tribunal examined whether a Singapore entity could claim DTAA exemption on capital gains from sale of Indian shares. It held that treaty benefits were unavailable as the entity lacked commercial substance and functioned as a shell or conduit.
The decision reiterates that reassessment cannot be initiated on borrowed satisfaction or presumptions. Independent application of mind by the Assessing Officer is mandatory for a valid reopening.
