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 Delhi held that granting blanket 153D approval without independent examination vitiates assessments. approvals under section 153D must be individualized and carefully considered.
The Telangana High Court ruled that Section 148 notices for central charge cases must follow the faceless procedure under the Finance Act, 2021, quashing JAO-issued notices.
The Court held that the approval granted for multiple search assessments was issued in a consolidated, mechanical form without case-specific consideration. It noted that Section 153D requires meaningful application of mind, which was absent in the approval examined by the Tribunal. The appeals were dismissed as no substantial question of law arose.
The Tribunal found that the authorities mechanically endorsed a factually incorrect premise, resulting in an unjustified DVO reference. Such a negligible 1.71% variation could not support an unexplained-investment addition under Section 69. Due to non-application of mind throughout the process, the 153A assessment was struck down entirely.
ITAT held that additions under section 153A cannot be made if no incriminating material is found at the assessee’s premises; third-party documents should be invoked via section 153C.
The Department could not produce a single document seized from the assessee, relying only on third-party statements, which are not incriminating material. The JCIT’s same-day clearance of multiple assessments without analysis led to the assessments being quashed.
The JCIT granted approval despite receiving only draft orders and no supporting evidence, demonstrating a mechanical process. The Tribunal held that such superficial approval violates judicial standards, leading to the quashing of all assessments.
The Tribunal held that section 69A requires unexplained money or valuables to be found; since only documents showing commission were seized, invoking section 69A was invalid. Only 20% of gross commission was allowed as taxable income.
ITAT held that the AO’s verification of seized material, statements, and bank records constituted proper enquiry. Key takeaway: Section 263 cannot be invoked merely because the PCIT prefers a different view.
The ITAT held that approvals granted under Section 153D without genuine application of mind are invalid, quashing multiple assessment orders. Key takeaway: mechanical or blanket approvals violate procedural requirements and render assessments null.
