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...
ITAT Chennai held that penalty under section 271(1)(c) of the Income Tax Act not sustainable since the additional income offered by the assessee was voluntary and addition is not based upon incriminating material seized during the course of search. Accordingly, order of CIT(A) upheld and appeal of revenue dismissed.
The Tribunal held that cash deposits were fully supported by stock records and sales invoices, proving they were genuine business receipts. It ruled that Section 68 cannot apply to recorded turnover already taxed.
CIT(A)’s order upheld; assessee acted as a middleman, and no evidence supported AO’s mechanical addition. Only Rs.15.42 lakh as brokerage recognized.
The Tribunal ruled that Explanation 5A applies only when the assessee is found possessing undisclosed tangible assets, which was not established. Since no such assets were discovered and the additions came from routine assessments, the penalty under section 271(1)(c) could not stand. This clarifies that the deeming fiction under Explanation 5A is not automatic.
Karnataka High Court held that blocking of Electronic Credit Ledger invoking rule 86A of Central Goods and Services Tax Rules [CGST Rules] without granting pre-decisional hearing and without providing reasons to believe is impermissible. Accordingly, order is quashed.
The Tribunal held that once sales are accepted and basic supporting documents exist, only the profit element in alleged bogus purchases can be taxed. It upheld a 6% GP addition and rejected the Revenue’s demand for 100% disallowance.
Bombay High Court held that grant of approval under section 153D of the Income Tax Act cannot be merely a ritualistic formality. Thus, proceedings u/s. 153A, based on approval u/s. 153D granted without application of mind, is vitiated.
The Tribunal quashed penalties for AYs 2009-10 and 2012-13, holding that show-cause notices must clearly specify the charge under Section 271(1)(c). Vague notices violating natural justice cannot sustain penalties. This reinforces the strict requirement for specificity in penalty proceedings.
The ITAT quashed assessments under Section 153A due to ex-parte orders, mechanical Section 153D approvals, and failure to give the assessee an opportunity to be heard, emphasizing the importance of natural justice in tax proceedings.
The Tribunal dismissed the appeal against disallowance of cash payments in a film production and real estate business. Since the assessee voluntarily offered 20% initially and later 80% of cash expenses as income, the additions were valid. The ruling emphasizes that self-conceded income cannot be contested in later appeals.
