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 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 ...
Income Tax : The ITAT upheld ₹90 lakh addition as the assessee failed to establish genuineness and creditworthiness of the transaction. The r...
Income Tax : In the absence of proper compliance with Section 65B and failure to establish a clear chain of custody, the digital evidence relie...
Income Tax : The issue was whether proceedings under Section 153C were time-barred. The Tribunal held that the assessment fell outside the limi...
ITAT Delhi held that notice under section 274 r.w.s. 271(1)(c) of the Income Tax Act issued without specifying the specific charge or limb i.e. without striking off the irrelevant limb is erroneous. Accordingly, penalty order u/s. 271(1)(c) cannot be sustained.
ITAT Delhi held that assessment under section 153A of the Income Tax Act based on common approval under section 153D of the Income Tax Act is non-est in the eye of law. Hence, the same is liable to be quashed.
Approval under Section 153D was invalid, as it was granted mechanically and collectively for several years, without independent application of mind. Such perfunctory approval defeats the statutory safeguard intended by the legislature. Consequently, the entire proceedings and assessments were quashed.
ITAT Chandigarh deletes ₹1.12 Cr addition for Northern Royalty Co. u/s 153C. Assessee’s revised profit (14-15%) was far higher than the 1.47% profit indicated by seized mining records. Arbitrary 18% NP rate rejected; consistency upheld. Revised return accepted.
ITAT Delhi quashes search assessments for Jagat Group, ruling that a single, consolidated approval letter for multiple assessees and years under Section 153D was invalid and mechanical.
ITAT Delhi quashed Balaji Metal Tech’s assessment, ruling it void due to mechanical approval, wrong section use (143(3) instead of 153C), and failure to mention DIN in the order.
ITAT Delhi quashes search assessments, ruling consolidated S. 153D approval for multiple assessees was mechanical, violating judicial mandate for independent application of mind.
Sanjay Garg Vs DCIT (ITAT Delhi) Assessee challenged assessments framed u/s 153A r.w.s. 143(3) on the ground that mandatory approval u/s 153D was granted mechanically without proper application of mind. AO had made an addition of Rs.50,00,000/- as unexplained money u/s 69, which was confirmed by CIT(A)-24, New Delhi vide order dated 28.02.2025. Before Tribunal, […]
ITAT Delhi annuls tax assessments on Nanak Chand Tayal, ruling that the blanket, mechanical approval under Section 153D was invalid and against judicial precedents from Delhi and Orissa High Courts.
The Income Tax Appellate Tribunal (ITAT), Raipur Bench, has quashed the assessment against Pawan Kumar Agrawal, ruling that the mandatory prior approval under Section 153D of the Income Tax Act.