Income Tax : This guide explains when penalties can be imposed under various provisions of the Income-tax Act, 1961. It also outlines the appli...
Income Tax : ITAT Mumbai held that penalty under Section 270A cannot be levied merely because income was estimated after rejection of books. Si...
Income Tax : The article explains how transactions between associated domestic entities exceeding ₹20 crore must comply with arm's length pri...
Income Tax : The Tribunal ruled that non-specification of the precise statutory charge under sections 270A(2) and 270A(9) violated principles o...
Income Tax : Budget 2026 proposes allowing taxpayers to file an updated return even after receiving a reassessment notice under Section 148. Wh...
Income Tax : Explore amendments to section 253 of Income-tax Act, adjusting time limits for filing appeals to the Income Tax Appellate Tribunal...
Income Tax : ITAT Delhi held that IT, salary and travel reimbursements without any profit element were not taxable and deleted the disallowance...
Income Tax : ITAT held that an Assessing Officer cannot substitute the DCF method chosen under Rule 11UA with the NAV method without legal just...
Income Tax : ITAT held ₹33 crore settled rights over the entire land, allowing full indexed acquisition cost and rejecting proportionate rest...
Income Tax : ITAT excluded EDCIL, Just Dial, Info Edge and India Exposition Mart as transfer pricing comparables due to functional differences ...
Income Tax : The Tribunal ruled that a penalty notice lacking a specific allegation of under-reporting, misreporting, or the applicable clause ...
The dispute concerned whether reimbursements from an associated enterprise justified a transfer pricing adjustment using the profit split method. The Tribunal set aside the adjustment, directing a fresh FAR analysis before determining ALP.
No on-money addition was made in the cases of other co-owners of the same property. The ITAT held that the Revenue cannot adopt a contradictory stand on identical facts.
ITAT Jaipur confirmed that Section 270A(6)(b) exclusion is inapplicable when accounts are incorrect or incomplete. Key takeaway: defective records make estimated disallowances liable to penalty.
Gattula Lakshmi Madhavi Vs ACIT (ITAT Visakhapatnam) Central Circle Cannot Assume Reassessment Powers — Section 148 Notice Issued Outside Faceless Regime Held Void The Visakhapatnam Bench of the ITAT quashed the reassessment framed under Section 147 and consequential penalties under Sections 270A and 271AAC in the case of Gattula Lakshmi Madhavi v. ACIT, holding that […]
The issue was whether penalty could be sustained when the notice alleged under-reporting but the order punished misreporting. The Tribunal held such variance impermissible, rendering the penalty void.
ITAT held that refusal to admit evidence due to factory sealing and death of the assessee was unjustified and ordered fresh assessment after proper verification.
Where income admitted in section 153C proceedings is accepted in assessment, penalty still requires strict compliance with section 270A. Absence of a specific misreporting charge defeats penalty levy.
ITAT Mumbai held that section 70 of the Income Tax Act allows first setting off the short term capital loss against the non STT gains taxable at thirty percent, and then applying the balance against the STT gains taxable at fifteen percent. Accordingly, appeal stands allowed.
The Tribunal held that an assessment under section 153C cannot go beyond the material specified in the satisfaction note. Since additions were based on different material, the entire assessment was quashed.
The Tribunal ruled that advisory and consultancy services could not be taxed as Fees for Included Services because no technical knowledge was transferred to clients.