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 Chennai held that assessee is needs to establish the expenditure which is unreasonably high. Thus, additional evidence filed for expense pertaining to ‘shortage and quality cuts’ needs complete verification. Accordingly, matter remanded back to AO.
The Tribunal ruled that cash deposits routed through a partners personal bank account were explained as firms business receipts. Without evidence of undisclosed sources, Section 69A addition cannot be made.
The Tribunal ruled that once cash sales are recorded in books and included in declared turnover, separate addition of deposits would result in double taxation. The entire ₹4.74 crore addition was deleted.
The Tribunal found no infirmity in the CIT(A)s detailed order deleting additions based on proper verification of evidence. All grounds raised by Revenue were rejected, and cross-objection became infructuous.
While noting deficiencies in supporting evidence, the ITAT found that entire addition of ₹50.90 lakh was not sustainable. The addition was restricted to 10% of purchases due to absence of book rejection.
Unexplained cash deposits and rent discrepancies led to rejection of books under section 145(3). However, the Tribunal held that estimating profits at 1% was excessive and moderated it to 0.50%.
Additions based on survey-time valuation of machinery were deleted as the Assessing Officer had not rejected the books of account. Prior binding orders in the same case were followed, reaffirming settled law.
The Tribunal held that additions based solely on a survey statement, without corroborative evidence, are unsustainable. Development expenses were largely allowed, with only a reasonable estimated disallowance retained.
The tribunal ruled that cash deposits sourced from recorded cash sales and bank withdrawals were genuine. It held that partial, ad-hoc additions without rejecting books of account are unsustainable.
Reopenings based on assumptions, conjecture, or generalized allegations were struck down. The ruling reiterates that reasons must show tangible material, application of mind, and a live nexus with escaped income.
