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 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.
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.
