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 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.
The Tribunal held that commission income cannot be computed on internal or circular banking transactions. It reduced the commission rate from 1.75% to 0.47% and directed recomputation after verification. The ruling emphasizes accurate determination of real in-come.
The Delhi High Court upheld the ITAT’s decision annulling the assessment after finding that statutory approval under Section 153D was granted without proper application of mind.
The Delhi High Court upheld the ITAT s ruling that assessment orders were invalid because the approving authority granted Section 153D approval mechanically without examining the records.
The Tribunal held that approval granted under Section 153D without application of mind was invalid. As a result, search assessments framed under Section 153C for multiple years were quashed.
ITAT Delhi upheld CIT(A) s order holding that reassessment under Section 153A cannot stand without incriminating material seized from the assessee. The Revenue’s appeal was dismissed.
ITAT Delhi held that recording a single satisfaction note for multiple assessment years violates Section 153C requirements. As no year-specific incriminating material was identified, the assessments were quashed along with the related penalty.
The Tribunal set aside the assessment after finding that a combined approval under Section 153D for multiple years vitiated proceedings. It held that such approval renders the assessment legally unsustainable.
ITAT held that the Assessing Officer failed to record proper satisfaction linking seized material to the assessee’s income. Consequently, proceedings under Section 153C were quashed.
