Income Tax : Smt. Ranjana Kumari/Kalta Vs DCIT/ACIT (Central) (ITAT Chandigarh) The appeals involved three assessees belonging to the Kalta Gro...
Income Tax : Learn the updated provisions governing rectification, assessments, reassessments, and appeals under the Income-tax Act. This guide...
Income Tax : The article explains how the Finance Acts, 2025 and 2026 have reshaped the Updated Return regime under Section 139(8A). It highlig...
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...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
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...
ITAT Ahmedabad restored a case where the CIT(A) upheld a major loss disallowance stemming from client code modification (CCM) without proper hearing. The Tribunal found the CIT(A) failed to consider that the addition was based on unsubstantiated claims from a report, directing a fresh hearing to examine evidence of genuine trading.
ITAT Rajkot confirmed that for a small trader opting for Section 44AD, the presumptive income covers the cash deposits related to the business cycle, making any separate addition for unexplained money (Section 69A) unjustifiable. The entire addition was deleted as the tax authorities acted on mere suspicion without bringing any contrary evidence to disprove the business nature of the deposits.
ITAT Ahmedabad ruled that while purchases from a blacklisted entity were not fully proven, the entire amount couldn’t be added to income as corresponding sales were accepted. Following Gujarat High Court precedents, the Tribunal restricted the addition to a 5% profit markup over the declared Gross Profit rate of 12.63%, thereby deleting the majority of the original Rs. 92,20,100 addition.
The Tribunal held that the Jurisdictional AO lacked the legal authority to issue the Section 148 notice after the CBDTs notification mandating the Faceless AO. Since the foundation of the reopening was flawed, the subsequent additions of over ₹1.5 Crore were deleted, and the entire assessment order was quashed.
ITAT Hyderabad remanded a reassessment case to verify the dispatch date of the Section 148 notice (speed post/email). The ruling, guided by the Delhi HC s Suman Jeet Agarwal case, states the date of delivery to the post office determines the notice’s validity.
ITAT Hyderabad deleted the Capital Gains addition in AY 2016-17, ruling that conditional possession under a JDA for mere development is NOT transfer u/s 2(47)(v). Tax is due only when full possession is handed over, confirming taxability in AY 2019-20.
The Tribunal partly allowed the appeal, asserting that once supporting documents are filed, genuine capital expenses like a boundary wall cannot be dismissed as bogus. The judgment confirms that only costs directly enhancing the asset’s value (like construction) are eligible as a cost of improvement, leading to the disallowance of security guard charges.
The Income Tax Appellate Tribunal (ITAT) Chennai ruled in the case of Late Ramasamy Pongianna Gounder Desamani Vs ITO that a loan from one company to another, where a common shareholder holds less than 20% of the voting power in the borrowing company, cannot be taxed as deemed dividend under Section 2(22)(e) of the Income-tax Act, 1961.
The ITAT set aside a Section 69A addition for unexplained cash payments, ruling that the AO must first verify the facts. The case was remanded because the assessee claimed an original allottee made the payment but failed to provide the plot’s transfer agreement as proof.
In a case involving a slum rehabilitation developer who did not file a return or maintain books, ITAT Pune applied a 12% estimated net profit rate on total gross receipts of Rs.1,93,64,405 to compute taxable income. This decision provides a precedent for estimating income in the construction sector where audited accounts are unavailable, allowing for usual business deductions.
