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...
Authorities added ₹8 crore as unexplained investment in the wrong year. The Tribunal confirmed that the cash component belonged to a prior year. The ruling stresses year-specific taxation of undisclosed transactions.
The Tribunal examined whether a single approval could cover multiple assessment years in search cases. It held that separate approvals are mandatory for each year. The ruling underscores strict procedural compliance under section 153D.
ITAT Delhi ruled that granting a common approval for several assessment years violates statutory safeguards. Search assessments collapse if approval is mechanical or omnibus in nature.
The tribunal held that prior approval under Section 153D was granted mechanically without application of mind. Such invalid sanction vitiated the entire search assessment, leading to quashing of the order.
The issue was whether settled losses could be ignored in a search assessment without incriminating material. The Tribunal held that the AO must start from the last assessed income and allow already determined losses.
The Tribunal ruled that CIT(A) exceeded jurisdiction by remanding a completed scrutiny assessment. The decision clarifies that remand powers apply only to Section 144 assessments, not regular ones.
The issue was whether common and ritualistic approval under section 153D can sustain search assessments. ITAT held that mechanical approval without independent application of mind vitiates the entire proceedings.
The notice under section 143(2) did not conform to the CBDT-prescribed format. ITAT ruled that a defective notice strikes at jurisdiction and invalidates the assessment.
The Tribunal held that revision under Section 263 cannot be exercised over a search assessment completed under Section 153C with proper approval under Section 153D. Unless such approval is shown to be erroneous, revisional jurisdiction does not arise.
The approving authority merely stated that records were perused without demonstrating scrutiny. The Tribunal held that mechanical sanction defeats the statutory purpose and nullifies the assessment.
