Income Tax : The ruling clarifies that unauthenticated digital chats and screenshots cannot form the sole basis of tax additions without proper...
Income Tax : Examine the legal disputes surrounding Section 153D approvals for tax assessments, including court rulings on mechanical approvals...
Income Tax : ITAT Ahmedabad held that WhatsApp chats indicating suppressed production for one month could not be extrapolated to the entire fin...
Income Tax : The ITAT Delhi held that a common satisfaction note covering multiple assessment years without year-wise incriminating material co...
Income Tax : The Tribunal held that contradictory third-party statements and unverified allegations cannot form the sole basis for taxing alleg...
Income Tax : The Kerala High Court remanded the matter after finding that the ITAT failed to expressly adjudicate the challenge to the validity...
Income Tax : The Mumbai ITAT held that reassessment proceedings under Section 147/148 were invalid where the case was based on search material ...
ITAT Ahmedabad held that WhatsApp chats indicating suppressed production for one month could not be extrapolated to the entire financial year without corroborative material. The Tribunal restricted the addition to the profit element for a three-month period.
The ITAT Delhi held that a common satisfaction note covering multiple assessment years without year-wise incriminating material could not validly confer jurisdiction under Section 153C. It consequently quashed the assessment.
The Tribunal held that contradictory third-party statements and unverified allegations cannot form the sole basis for taxing alleged on-money transactions. The ruling reiterates that suspicion cannot replace legally admissible evidence.
The Kerala High Court remanded the matter after finding that the ITAT failed to expressly adjudicate the challenge to the validity of approval under Section 153D. The ruling underscores the need for tribunals to address every material issue raised before them.
The Mumbai ITAT held that reassessment proceedings under Section 147/148 were invalid where the case was based on search material requiring action under Section 153C. The ruling reinforces that search-related assessments for third parties must follow the special procedure under Section 153C, not regular reassessment provisions.
ITAT Delhi held that consolidated approvals granted without application of mind under Section 153D were invalid. Consequently, the related assessment orders were declared void and quashed.
The Department argued that Section 292BC validated the approval despite alleged deficiencies, but the Tribunal rejected this contention. It held that the amendment could not apply to approvals granted before 1 April 2021. The ruling clarified that subsequent legislative changes could not cure defects in earlier approvals.
Delhi ITAT held that assessments under Section 153C were invalid where the satisfaction note for the non-searched person was recorded after 01.04.2021. The Tribunal ruled that Section 153C(3) barred such proceedings, rendering the assessments void.
The ITAT held that a common approval granted mechanically for multiple assessees did not constitute a valid approval under Section 153D. As a result, the assessment order was quashed and the Revenue’s appeal was dismissed.
The Tribunal held that the approval under Section 153D reflected no proper application of mind and was issued in a mechanical manner. As a result, the assessments framed pursuant to such approval were quashed.
