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...
Emphasising strict compliance, the Tribunal ruled that assessments under section 153A without prior section 153D approval are invalid. Cross-objections became infructuous once Revenue appeals were dismissed.
The Tribunal held that a common, perfunctory sanction under Section 153D is invalid. The key takeaway is that lack of independent application of mind vitiates search assessments entirely.
It was ruled that granting a single, common approval for multiple assessment years violates the mandate of Section 153D. Each assessment year requires separate and conscious examination by the approving authority.
The Tribunal clarified that approval under section 153D is an administrative safeguard and need not contain elaborate reasoning. Allegations of mechanical approval fail without concrete evidence of non-application of mind.
The tribunal held that assessment under section 153C cannot be initiated without seized material belonging to or relating to the assessee. Third-party statements and assumptions, without incriminating evidence, were held insufficient to confer jurisdiction
The Tribunal held that additions in a search assessment cannot survive without incriminating material. Mere repetition of an annulled earlier assessment was found legally unsustainable.
The Tribunal examined whether prior approval under Section 153D was granted after due application of mind. It held that mechanical and routine approval invalidates the assessment, rendering the search assessment void.
The Tribunal held that assessments beyond the permissible six-year block under section 153C are invalid. Proceedings were quashed as the relevant years fell outside the statutory limitation.
The tribunal held that reassessment initiated through a jurisdictional officer instead of the mandatory faceless mechanism was invalid. Notices under Section 148 issued after 01.04.2021 must follow the faceless scheme, failing which the entire assessment collapses.
The issue was whether six years of search assessments could stand when the first appeal was dismissed ex-parte. ITAT held that denial of meaningful hearing violates natural justice and remanded the matters for fresh adjudication.
