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 ruled that a 76/23 split in chats reflected proposed refurbishment costs, not undisclosed cash consideration. In absence of corroborative material, addition under Sections 69 and 115BBE was held unsustainable.
ITAT held that a portion of cash paid could reasonably be sourced from accumulated withdrawals from joint bank accounts. The remaining unexplained amount was reduced on an estimated basis.
The Tribunal held that assumption of jurisdiction under Section 153C was invalid due to a defective and consolidated satisfaction note. As the mandatory requirement of year-wise satisfaction was not met, the entire assessment was quashed.
The Tribunal noted that the subject line of the approval letter excluded the concerned assessment year, evidencing lack of scrutiny. It held that such defective approval invalidates the assessment.
The approving authority issued one common approval for multiple years without demonstrating examination of records. The Tribunal ruled such ritualistic approval vitiates the entire assessment.
ITAT ruled that reliance on statements without offering cross-examination and without supporting evidence violates principles of natural justice. Additions under Sections 69A and 153C were set aside.
The Court held that reassessment based solely on material seized in a third-party search must proceed under Section 153C, not Section 148. Notices issued under the general reassessment provision were set aside.
The issue was whether purchases recorded by the assessee were genuine. The Tribunal held that seized Tally data and statements proved bogus purchases, justifying full addition.
A single approval was granted for multiple years without examining seized material or draft orders. The Tribunal ruled that such omnibus approval vitiates proceedings under Sections 153A/143(3).
The Tribunal held that reopening AY 2012–13 after a post-2021 search was barred by limitation. Applying Supreme Court guidance, it ruled that older limitation periods protect concluded assessments from retrospective reopening.
