Income Tax : This document provides a complete reference on compounding of offences, including application procedures, offence-wise charges, re...
Income Tax : The FAQs explain the revised CBDT guidelines on compounding offences under the Income-tax Act effective from 17 October 2024. They...
Income Tax : The FAQs explain the prosecution provisions under the Income-tax Act, covering offences such as tax evasion, non-payment of TDS/TC...
Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...
Income Tax : Courts are divided on whether the DRP-specific deadline under Section 144C(13) overrides the general assessment time bar in Sectio...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : ITAT Delhi quashed a Section 153C assessment, holding that a consolidated and defective satisfaction note invalidated jurisdiction...
Income Tax : ITAT held that a registered sale deed without corroborative evidence is not incriminating material and cannot support additions in...
Income Tax : ITAT held reassessment under Sections 147/148 invalid because it was based on a pre-1 April 2021 third-party search, requiring pro...
Income Tax : ITAT Mumbai quashed a Section 148 notice issued after the limitation under the first proviso to Section 149, holding the reassessm...
Income Tax : ITAT held that penalty under Section 271D cannot survive where the Assessing Officer failed to record satisfaction in the assessme...
Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...
Smt. Satyabhama Vs DCIT (ITAT Hyderabad) The Hyderabad ITAT deleted the addition of ₹16.55 lakh u/s 69A, holding that cash found during search was duly explained by earlier accepted cash balance. The Tribunal also condoned a 97-day delay, adopting a liberal approach considering the assessee’s age, lack of digital access, and procedural difficulties. On merits, […]
The Tribunal held that additions under Section 153C cannot be sustained when based on unverified third-party statements and documents. It found the evidence lacked credibility and was not corroborated. The ruling highlights strict evidentiary standards in search-based assessments.
The tribunal held that cash deposits cannot be treated as unexplained when sufficient recorded cash receipts exist. Once books support availability, Section 68 additions fail.
The Tribunal held reassessment invalid as the alleged escaped income did not exceed ₹50 lakh required for extended limitation. It ruled that invoking extended time under Section 149 without satisfying this condition is illegal.
ITAT Mumbai deleted Section 69 addition on alleged on-money, holding third-party statements and unverified pen drive data lack evidentiary value without corroboration or cross-examination, upholding natural justice.
The Tribunal noted that statements relied upon were later retracted and lacked corroboration. It held that such statements cannot form sole basis of addition. The ruling emphasizes need for supporting evidence in tax proceedings.
The tribunal ruled that revisionary powers cannot be exercised without questioning the statutory approval under Section 153D. Absence of such examination renders Section 263 action invalid.
The High Court held that once the assessee failed to explain the source, addition was justified only to the extent of cash actually seized. It ruled that the AO cannot arbitrarily add a higher amount than the proven seized sum.
ITAT ruled that interest disallowance cannot be made when sufficient interest-free funds are available. The key takeaway is that availability of own funds overrides assumptions of borrowed fund usage.
The court examined whether buy-back of shares below fair market value attracts Section 56(2)(x). It held that buy-back leads to extinguishment of shares, not acquisition of property, making the provision inapplicable.
