Income Tax : Practical guide to tax audit under Section 44AB for trader assessees, covering groundwork, data analysis, compliance checks, and f...
Income Tax : Summary of the judgement About the assessee The assessee is a limited liability company engaged in the business of manufacture and...
Income Tax : Deduction of TDS and Taxability of the same; An Analysis of section 198 and 145 of Income tax 1961. As per basic understanding, th...
Income Tax : Self assessment - The assessee is required to make a self assessment and pay the tax on the basis of the returns furnished. Any ta...
Income Tax : ♦ Section 145A of Income Tax Act, 1961 ‘145A. Method of accounting in certain cases.—Notwithstanding anything to the contra...
Income Tax : ITAT Hyderabad held that assessment orders passed pursuant to earlier remand directions were barred by limitation under Section 15...
Income Tax : ITAT Delhi held that Section 69A could not be invoked where the Assessing Officer himself accepted that transactions were recorded...
Income Tax : The Tribunal held that revisionary powers cannot be used to substitute the AO’s view with that of the Pr. CIT. It emphasized tha...
Income Tax : The Tribunal upheld reopening under Section 147 as Form 26AS reflected substantial contract receipts despite no return being filed...
Income Tax : Transfer of passive infrastructure (PI) assets under a court-approved scheme of demerger without consideration qualified as a gift...
ITAT Hyderabad held that assessment orders passed pursuant to earlier remand directions were barred by limitation under Section 153. The Tribunal set aside all consequential transfer pricing assessment orders dated 06.12.2024.
ITAT Delhi held that Section 69A could not be invoked where the Assessing Officer himself accepted that transactions were recorded in the books of account. The matter was remanded for limited verification of sales records and related documents.
The Tribunal held that revisionary powers cannot be used to substitute the AO’s view with that of the Pr. CIT. It emphasized that such substitution is beyond Section 263. The decision protects independent assessment decisions.
The Tribunal upheld reopening under Section 147 as Form 26AS reflected substantial contract receipts despite no return being filed. It ruled that such information constitutes valid grounds for belief of income escaping assessment.
Transfer of passive infrastructure (PI) assets under a court-approved scheme of demerger without consideration qualified as a gift under Section 47(iii), thereby legitimizing the claim of depreciation on such assets.
The Tribunal held the assessment invalid as no mandatory notice under Section 143(2) was issued. The key takeaway is that absence of such notice renders the entire assessment void.
The issue was whether cash deposits from business sales could be treated as unexplained income under Section 68. ITAT held that recorded cash sales forming part of turnover cannot be taxed as unexplained credits.
ITAT Delhi held that approval from the PCCIT or PDGIT is mandatory, as provided u/s 35(2AB)(iv) of the Act. Since such mandatory approval of R&D facility from the PCCIT or PDGIT was not obtained by the assessee therefore, weighted deduction u/s 35(2AB) of the Act cannot be allowed.
The Tribunal held that AMC services involving indeterminate acts over a defined period must follow the straight-line method under Section 43CB. The addition of ₹4.26 crore towards AMC receipts was therefore deleted.
The Tribunal held that cash deposits recorded in regular books of account cannot be treated as unexplained investments under section 69. Since the books were not rejected and no contrary evidence was produced, the addition was deleted.