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Income Tax : Learn the updated provisions governing rectification, assessments, reassessments, and appeals under the Income-tax Act. This guide...
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Income Tax : The Supreme Court has remitted reassessment cases for fresh consideration after the retrospective insertion of Section 147A, leavi...
Income Tax : This article explains why reassessment proceedings may be invalid if the Assessing Officer merely relies on Investigation Wing rep...
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Income Tax : Discover how Finance Act 2021 revamped assessment and reassessment procedures under Income-tax Act, impacting notices, time limits...
Income Tax : Humble Representation for modification of Section 151 of the Income Tax Act relating to Sanction for issue of Notice under sec. 14...
Income Tax : Income Tax Gazetted Officers’ Association requested CBDT to issue Clarification in respect of the judgement of Hon’ble Supreme...
Income Tax : In view of Indiscriminate notices by income Tax Department without allowing reasonable time it is requested to Finance Ministry an...
Income Tax : Where unaccounted sales were established through seized material, only the net profit embedded therein was liable to tax, and not ...
Income Tax : ITAT Mumbai remanded the case to examine whether Section 56(2)(x) applied based on the agreement date and to consider refund of ex...
Income Tax : ITAT Bangalore remanded a Section 69A addition after holding that an APMC commission agent's entire sale proceeds could not be tre...
Income Tax : ITAT Kolkata condoned appeal delay, set aside the CIT(A)'s order, and remanded the assessment for fresh adjudication after grantin...
Income Tax : ITAT Mumbai quashed reassessment after finding no Section 143(2) notice and that the AO issued a final order disguised as a draft ...
Income Tax : The department has identified high-risk cases through its Insight Portal for AYs 2022-25. It directs officers to initiate reassess...
Income Tax : ITAT Chandigarh held that ITO Ward-3(1), Chandigarh had no jurisdiction to issue notice to an NRI and hence consequently the asses...
Income Tax : Explore the latest guidelines for issuing notice under Section 148 of the Income Tax Act, 1961. Understand key procedures, amendme...
Income Tax : Explore e-Verification Instruction No. 2 of 2024 from the Directorate of Income Tax (Systems). Detailed guidelines for AOs under I...
Income Tax : Supreme Court in the matter of Shri Ashish Agarwal, several representations were received asking for time-barring date of such cas...
The Tribunal held that income could not be assessed in the hands of a firm that had ceased to exist years earlier. Since the deposits belonged to the successor proprietorship concern, the addition was deleted.
The Tribunal ruled that Section 69A cannot be mechanically invoked without establishing that the deposits constitute unexplained income. Evidence of genuine business activity justified taxation only of the profit component.
ITAT Mumbai ruled that additions under Section 69 cannot be sustained merely on suspicion when the entire property investment is supported by documentary evidence. The Tribunal emphasized that conjectures cannot substitute proof.
Additions made by attributing the commission income earned by PSPL as undisclosed income of the Assessees were held unsustainable in law and were directed to be deleted across all relevant assessment years as Revenue had failed to establish inflation of purchase prices; accrual of PSPL’s commission income to assessees; any flow back of funds to the Assessees; or that PSPL was a sham or fictitious entity.
The Tribunal ruled that reassessment proceedings initiated on the basis of an invalid Section 148 notice were void ab initio. It observed that where jurisdiction itself is lacking, the proper course is to annul the proceedings rather than remand the matter. The decision underscores the mandatory nature of statutory limitation periods.
The ITAT Chennai ruled that funds received by a Chartered Accountant for remitting clients’ taxes could not be treated as unexplained money. Documentary evidence showing corresponding tax payments led to deletion of the additions.
ITAT Hyderabad held that dismissal of an appeal under section 249(4)(b) was unjustified where the assessee claimed that the receipts were exempt retirement benefits and no advance tax liability arose. The matter was remanded to the AO to verify the nature and taxability of the amounts reflected in Form 16.
Delhi ITAT held that assessments under Section 153C were invalid where the satisfaction note for the non-searched person was recorded after 01.04.2021. The Tribunal ruled that Section 153C(3) barred such proceedings, rendering the assessments void.
The Tribunal found that none of the purchasers examined by the Department had admitted making cash payments to the assessee. In the absence of statements, receipts, diaries, or other incriminating material, the allegation of on-money remained unsubstantiated. The addition based on presumptions was therefore set aside.
The Court held that reassessment proceedings cannot be sustained merely on the basis of an unsigned and unauthenticated loose paper lacking any connection with the taxpayer. In the absence of corroborative evidence linking the petitioner to the alleged transaction, the reopening notice and reassessment order were set aside.
