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...
The Tribunal held that an assessment under section 153C cannot go beyond the material specified in the satisfaction note. Since additions were based on different material, the entire assessment was quashed.
The Tribunal held that a summary and presumptive approval under Section 153D vitiates the entire assessment. Lack of independent application of mind by the approving authority renders the assessment non-est.
The Tribunal held that mandatory prior approval granted in a routine and non-speaking manner violates statutory requirements. Assessments framed on such approval were found legally unsustainable.
The issue was whether entire alleged bogus purchases should be added as income after a search assessment. The Tribunal held that where consumption and records are not disputed, only the profit element can be taxed, not the full purchase value.
ITAT Chandigarh held that passing of final assessment order under section 153A of the Income Tax Act without issuing draft assessment orders under section 144C of the Income Tax Act is untenable. Accordingly, final assessment order u/s. 153A is quashed.
The issue before the Court was whether a bare approval lacking application of mind could sustain proceedings under Section 153C. The Court held that mechanical approval vitiates the proceedings, reaffirming that valid approval is a mandatory jurisdictional requirement.
ITAT Jaipur held that assessment under section 153C of the Income Tax Act stands quashed due to lack of jurisdiction since there was no transfer of the case of the assessee from Delhi to Jaipur.
The issue was whether section 153C could extend beyond six years without discovery of an undisclosed asset of ₹50 lakh or more. The ITAT held that in absence of such asset-based satisfaction, extended jurisdiction is invalid.
The issue was whether a single, consolidated approval under section 153D for multiple assessees is legally valid. The ITAT held that such mechanical approval shows no application of mind and vitiates the entire search assessment.
The issue was whether penalty could survive after the underlying assessment was quashed. The ITAT held that once the 153A assessment was annulled, the penalty under section 270A automatically fell.
