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 : CBDT issues new compounding guidelines simplifying process, eligibility, charges, and procedures under the Income-tax Act from Oct...
Income Tax : A summary of prosecution offences under Chapter XXII of the Income Tax Act (Sections 275A to 280), detailing the rigorous imprison...
Income Tax : CBDT's new Compounding of Offence Guidelines (2024) simplify the process but maintain strict compliance rules. Learn about eligibi...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : The Tribunal held that loan repayment cannot be treated as unexplained cash credit under section 68. The addition was deleted as i...
Income Tax : The issue was whether a notice granting less than the statutory minimum time is valid. The tribunal held that giving less than 7 d...
Income Tax : Reassessment proceedings was invalid for a notice issued beyond three years without the sanction of the prescribed higher authorit...
Income Tax : The Tribunal held that unsigned excel sheets without supporting evidence cannot justify additions. It ruled that absence of corrob...
Income Tax : ITAT Mumbai deletes Section 69 additions holding that third-party excel sheets and statements without corroborative evidence lack ...
Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...
The tribunal reversed the CIT(A)’s decision for wrongly quashing assessment due to lack of notice under Section 143(2). It held that Section 263 proceedings are a continuation of original assessment.
The court held that parties cannot introduce additional evidence as a matter of right under Rule 29. The ITAT’s acceptance of Revenue-filed evidence and remand order was set aside as beyond jurisdiction.
The case addressed whether a special audit can be ordered without establishing complexity or defects in accounts. The Court examined whether mechanical invocation of Section 142(2A) without proper justification is legally sustainable.
The Court ruled that the reassessment notice was invalid as it exceeded the statutory 10-year limit under Section 153A. It clarified that the search year must be included in computing the extended limitation period.
ITAT held that reassessment without issuing notice under Section 143(2) is invalid, even if return was filed late. The ruling emphasizes that issuance of notice is mandatory and absence of it makes the assessment void.
The ITAT upheld ₹90 lakh addition as the assessee failed to establish genuineness and creditworthiness of the transaction. The ruling emphasizes the burden of proof on taxpayers in cash credit cases.
The issue was whether a single satisfaction note can cover multiple assessment years under Section 153C. The Tribunal held that absence of year-wise satisfaction renders the proceedings invalid. The key takeaway is that jurisdiction requires specific satisfaction for each year.
The issue was whether reassessment under Section 147 is valid after a search. The ITAT held it invalid, ruling that only Section 153A applies post-search, making the reassessment void.
The Tribunal held that protective additions cannot be sustained without establishing the assessee as the actual beneficiary of cash credits. It upheld deletion where ownership was not proven.
The Tribunal allowed deduction of royalty paid for use of a logo, noting that no specific defect was found in the supporting evidence. It held that the expenditure could not be disallowed merely on grounds of justification without examining its business purpose.