Income Tax : ITAT held that where sales are not disputed, entire purchases cannot be disallowed. Only 15% profit element was taxed, reinforcing...
Income Tax : The Tribunal quashed reassessment proceedings as they were based on a mere change of opinion without any fresh tangible material. ...
Income Tax : The issue involved levy of late fees on TDS returns processed before statutory amendment. The Tribunal held that absence of enabli...
Income Tax : The Tribunal held that valuation without giving the assessee an opportunity to object violates natural justice. It remanded the ma...
Income Tax : The Tribunal condoned delay due to reasonable cause and addressed valuation mismatch. It remanded the issue for DVO-based reassess...
ITAT Mumbai held that penalty under Section 271(1)(c) cannot survive where bogus purchase additions are made purely on an estimated basis. Estimated profit disallowances do not prove concealment without concrete evidence.
The Tribunal ruled that failure to issue notice under Section 143(2) after receiving return in reassessment proceedings is a jurisdictional defect. The reassessment order was quashed.
The Tribunal ruled that long-term capital gains treated as bogus could not be added in a completed assessment year absent search-based incriminating evidence. Investigation reports alone were held insufficient.
The Tribunal ruled that rectification proceedings under Section 154 are limited to correcting apparent mistakes and cannot be a vehicle to dispute original additions. The appeal was therefore rightly rejected.
The Tribunal held that in completed assessments, no addition can be made under Section 153A without incriminating material found during search. The addition under Section 68 was annulled as jurisdiction was invalid.
The Tribunal ruled that mere circulation of funds among group entities does not prove round-tripping unless supported by cogent evidence. Suspicion alone cannot justify addition under Section 68.
The Tribunal found repeated factual errors in recorded reasons and notices. As the reopening lacked live nexus with escapement of income, it was struck down as a nullity.
ITAT ruled that mere reference to high-value transactions cannot justify reopening beyond three years. Absence of statutory conditions under Section 149(1)(b) rendered the reassessment void.
ITAT held that labeling transactions as accommodation entries without investigation is impermissible. With all three ingredients satisfied, the addition of ₹86.90 lakh was removed.
ITAT held that mere signature or rubber-stamp approval under Section 151 is invalid if it does not reflect independent satisfaction. The reassessment and consequent additions were quashed for lack of valid jurisdiction.
