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 : The Tribunal ruled that the Revenue must establish a direct connection between seized material and the assessee’s taxable income...
Income Tax : Delhi ITAT held that uncorroborated WhatsApp messages and digital chats cannot by themselves establish undisclosed cash transactio...
Income Tax : The tribunal ruled that revisionary powers cannot be exercised without questioning the statutory approval under Section 153D. Abse...
Income Tax : The ruling clarifies that unauthenticated digital chats and screenshots cannot form the sole basis of tax additions without proper...
Income Tax : ITAT Delhi held that granting of mandatory approval under section 153D of the Income Tax Act by Additional Commissioner of Income ...
The Tribunal ruled that the Revenue must establish a direct connection between seized material and the assessee’s taxable income before invoking Section 153C. Mechanical initiation of proceedings for multiple years was declared invalid.
Delhi ITAT held that uncorroborated WhatsApp messages and digital chats cannot by themselves establish undisclosed cash transactions. The Tribunal deleted additions made solely on presumptions without independent evidence.
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 ruling clarifies that unauthenticated digital chats and screenshots cannot form the sole basis of tax additions without proper verification and legal compliance.
ITAT Delhi held that granting of mandatory approval under section 153D of the Income Tax Act by Additional Commissioner of Income Tax in a mechanical manner and without due application of mind is an empty ritual. Thus, order held void-abinitio for want of valid approval u/s. 153D.
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.
In the absence of proper compliance with Section 65B and failure to establish a clear chain of custody, the digital evidence relied upon by the Revenue lacked legal admissibility and evidentiary value.
The issue was whether proceedings under Section 153C were time-barred. The Tribunal held that the assessment fell outside the limitation period and was therefore invalid.
The issue was whether a single satisfaction note for multiple years is valid under Section 153C. ITAT Pune held it invalid, ruling that separate satisfaction per year is mandatory, thereby quashing the entire assessment.
The Tribunal ruled that revision under Section 263 requires examination of approval granted under Section 153D. Without establishing any defect in such approval, the assessment cannot be termed erroneous. The decision limits arbitrary revision powers.
