Income Tax : The Tribunal held that additions under Section 69 cannot be sustained when based solely on third-party statements and unverified e...
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...
The ITAT held that an assessment and appellate order passed without effective participation, allegedly due to notices sent to a wrong email address, must be set aside and remanded for fresh adjudication.
The Tribunal admitted additional evidence where TDS credit was denied because it appeared in a different assessment year’s Form 26AS. The matter was remanded to the Assessing Officer to verify documents and allow credit as per law.
The Tribunal held that advance tax cannot be treated as delayed when the amount is debited from the taxpayer’s bank account on the due date. Interest under Section 234C was quashed as the delay in challan generation was beyond the assessee’s control.
The Tribunal remanded the case after finding that the addition was made solely on Investigation Wing inputs without proper verification or disclosure of details to the taxpayer.
Revenue argued that control and fixed hours created employment. The Tribunal ruled that such controls ensure discipline and contract enforcement, not employment. Result: TDS under Section 194J sustained.
The Revenue treated cash deposits as unexplained under Section 69A despite matching withdrawals and opening cash balance. The Tribunal ruled that redeposit of available cash cannot be taxed as unexplained income.
The ITAT ruled that ad-hoc estimation of sundry creditors as ceased liabilities is not permissible when purchases and trading results are accepted. Section 41(1) can be invoked only on proven remission or cessation, not assumptions.
The Tribunal held that reopening AY 2012–13 after a post-2021 search was barred by limitation. Applying Supreme Court guidance, it ruled that older limitation periods protect concluded assessments from retrospective reopening.
Since the reassessment notice was barred by limitation, the tribunal did not examine capital gains issues on merits. The ruling confirms that jurisdictional defects override substantive tax disputes.
Additions under Sections 68 and 69C were set aside after the Tribunal found the mandatory approval to be a mere formality. The ruling reinforces that Section 153D approval is not a procedural ritual.
