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...
Interest earned on funds kept in bank during business setup, when those funds were directly linked to the project, was a capital receipt and not taxable as “income from other sources
The case examined whether compensation paid to exit prior agreements was a sham arrangement. The Tribunal ruled it was a valid business decision that enabled higher sale consideration.
The Tribunal held that loan repayment cannot be treated as unexplained cash credit under section 68. The addition was deleted as it was based on incorrect classification of repayment as fresh loan.
The issue was whether a notice granting less than the statutory minimum time is valid. The tribunal held that giving less than 7 days violates mandatory provisions, rendering the notice and entire reassessment proceedings invalid.
Reassessment proceedings was invalid for a notice issued beyond three years without the sanction of the prescribed higher authority as prior approval must mandatorily be obtained from the authorities specified under Section 151(ii) and approval by the Principal Commissioner was not valid in such cases.
The Tribunal held that unsigned excel sheets without supporting evidence cannot justify additions. It ruled that absence of corroboration and cross-examination renders such documents unreliable.
ITAT Mumbai deletes Section 69 additions holding that third-party excel sheets and statements without corroborative evidence lack evidentiary value. Reopening based on unverified data and denial of cross-examination violates natural justice; entire additions quashed.
Addition under Section 68 could not be sustained where assessee has established the genuineness of a Non-banking financial company (NBFC) investor, and the AO failed to rebut such evidence or trace any money trail linking the assessee to the invested funds.
The Court examined whether reassessment based on search could extend beyond statutory timelines. It held that the notice for AY 2015–16 was issued beyond the permissible ten-year period. The ruling confirms that limitation provisions must be strictly followed.
The case examined whether documents found during search can be automatically attributed to the assessee. The Tribunal ruled that ownership and connection must be established through evidence. The decision underscores limits of statutory presumptions under Section 292C.
