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 ...
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.
Bombay High Court held that grant of approval under section 153D of the Income Tax Act cannot be merely a ritualistic formality. Thus, proceedings u/s. 153A, based on approval u/s. 153D granted without application of mind, is vitiated.
The ITAT quashed assessments under Section 153A due to ex-parte orders, mechanical Section 153D approvals, and failure to give the assessee an opportunity to be heard, emphasizing the importance of natural justice in tax proceedings.
Tribunal ruled that a single approval letter covering several assessment years violated statutory requirements. Key takeaway: Section 153D requires separate, reasoned approvals for each year.
The ITAT Ahmedabad quashed PCIT’s revisionary orders, holding that Section 263 powers cannot be used when the AO has made thorough enquiries. Revision requires demonstrable error prejudicial to revenue, not mere differences of opinion.
Because the approval was issued collectively for several years, the Tribunal found it invalid and allowed the appeal. The key takeaway is the necessity of separate approval for each year.
