Income Tax : ITAT held that a portion of cash paid could reasonably be sourced from accumulated withdrawals from joint bank accounts. The remai...
Income Tax : The Tribunal held that assumption of jurisdiction under Section 153C was invalid due to a defective and consolidated satisfaction ...
Income Tax : The Tribunal held that reassessment proceedings fail when the Assessing Officer abandons the issue forming the basis of reopening....
Income Tax : The Tribunal observed that ₹99.10 lakh allegedly added as unexplained credits may represent earlier year balances. The matter wa...
Income Tax : The approving authority issued one common approval for multiple years without demonstrating examination of records. The Tribunal r...
ITAT held that a portion of cash paid could reasonably be sourced from accumulated withdrawals from joint bank accounts. The remaining unexplained amount was reduced on an estimated basis.
The Tribunal held that assumption of jurisdiction under Section 153C was invalid due to a defective and consolidated satisfaction note. As the mandatory requirement of year-wise satisfaction was not met, the entire assessment was quashed.
The Tribunal held that reassessment proceedings fail when the Assessing Officer abandons the issue forming the basis of reopening. In such cases, other additions cannot be made without issuing a fresh notice under Section 148.
The Tribunal observed that ₹99.10 lakh allegedly added as unexplained credits may represent earlier year balances. The matter was remanded for verification to avoid wrongful taxation in the current assessment year.
The approving authority issued one common approval for multiple years without demonstrating examination of records. The Tribunal ruled such ritualistic approval vitiates the entire assessment.
The Tribunal confirmed the jurisdictional validity of reassessment based on new information. However, the addition was restored to ensure compliance with principles of natural justice and Section 250(6).
The Tribunal held that failure to indicate the precise charge in a Section 274 notice renders penalty proceedings unsustainable. Following jurisdictional High Court rulings, the penalty was set aside.
The Tribunal emphasized that the test under Section 57(iii) is one of purpose and connection. As the assessee demonstrated reasonable nexus between borrowings and interest income, the deduction was upheld.
Holding that Rule 46A mandates recording reasons and giving the Assessing Officer a chance to rebut new evidence, the Tribunal set aside the appellate order and remitted the issue.
ITAT Delhi held that the assessment order was invalid as it was not served in accordance with Section 282 and Rule 127. In absence of proof of proper service within limitation, the entire assessment was quashed as void.
