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 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.
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.
