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 ...
The Tribunal held that AY 2010-11 was outside the permissible ten-year assessment block computable under Section 153A. Applying the Delhi High Court’s interpretation in Ojjus Medicare, it found the notice itself invalid. As a result, the assessment proceedings were quashed and the appeals were allowed.
The case involved additions for alleged on-money in Godhavi land transactions based on a handwritten loose sheet. The Tribunal restored the matter for fresh consideration, highlighting issues relating to evidence and assessment findings.
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.
