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 Revenue invoked section 115BBE based on cash found during proceedings. However, the Tribunal found the foundational approval under section 153D defective. The entire assessment was therefore quashed.
ITAT Delhi held that mere Whatsapp messages showing demand do not justify Section 69A additions unless actual receipt of money is proved.
The Tribunal held that ritualistic approval under section 153D, without application of mind, vitiates search assessments. Mandatory supervisory approval must reflect genuine examination of draft orders.
The ITAT Delhi ruled that a single approval for seven assessment years under Section 153D, issued without application of mind, is invalid, quashing the related assessment orders. The case underscores the need for careful, year-specific scrutiny.
The issue was whether a completed assessment could be revised without identifying concrete errors. The Tribunal held that vague observations and absence of specific defects do not justify invoking section 263.
PCIT invoked section 263 against an assessment under section 153C. ITAT held that without challenging statutory 153D approval, revision is unsustainable, emphasizing that 153D is a statutory safeguard.
PCIT challenged a 153C assessment under section 263. ITAT held that without annulling statutory 153D approval, revision is unsustainable, confirming 153D as a statutory safeguard.
ITAT Delhi held that a single Section 153D approval for multiple assessees and years is impermissible, rendering all 153A and 153C assessments void ab initio.
ITAT held that mass same-day approval without reviewing records violated Section 153D. The ruling confirms that mechanical approvals invalidate 153A assessments.
The issue involved a common sanction letter covering multiple assessees and years, issued on the same day the AO sought approval. ITAT found this composite approval inconsistent with judicial mandates requiring individualized scrutiny. As a result, the assessment was declared void ab initio, making all additions infructuous.
