Income Tax : The Tribunal held that penalty under section 271(1)(c) cannot be imposed when errors are voluntarily corrected during assessment. ...
Income Tax : A summary of key penalties under the Income Tax Act for AY 2026-27, covering defaults from late filing and non-payment to misrepor...
Income Tax : ITAT Delhi held penalty u/s 271(1)(c) unsustainable as 54F exemption failed due to builder delay, not taxpayer’s fault. Full dis...
Income Tax : Understand why an income-tax penalty under Section 271(1)(c) is invalid if the charge isn't specified as concealment or inaccurate...
Income Tax : Learn how taxpayers can defer income tax penalty proceedings when quantum additions are under appeal. Understand legal grounds and...
Income Tax : The Committee recommends that the scope of Section 273B should be suitably enlarged to provide that penalty for concealment of inc...
Income Tax : The case addressed ambiguity in penalty proceedings where the specific charge was not identified. The Court upheld deletion of pen...
Income Tax : The case involved an ambiguous penalty notice that did not clarify whether the charge was concealment or inaccurate particulars. T...
Income Tax : The case involved penalty on disallowance of purchases treated as non-genuine and estimated at 12.5%. Tribunal ruled that estimate...
Income Tax : ITAT Mumbai remanded ₹95.81 lakh commission disallowance, holding that non-response to Section 133(6) notices alone cannot justi...
Income Tax : ITAT Mumbai held that CIT(A) cannot enhance income by introducing a new issue not examined by the Assessing Officer. The ruling cl...
Income Tax : Section 270AA of the Income-tax Act, 1961 (the Act) inter alia provides that w.e.f. 1 st April, 2017, the Assessing Officer, on an...
The issue was whether a holding company with no operating revenue could claim business expenses. The Tribunal held that making strategic investments to control subsidiaries is itself a business activity, allowing expenses and loss set-off.
The appellate authority had mechanically rejected additional evidence without reasons, resulting in denial of fair opportunity. The tribunal restored the quantum issue for reconsideration and quashed the consequential penalty.
The assessee neither filed returns nor responded to statutory notices, yet additions were deleted on appeal. ITAT held that absence of verification of source and compliance makes such deletion unsustainable.
The Revenue relied on alleged ₹4 crore unexplained investment to justify reopening beyond six years. The Tribunal ruled that even high-value allegations cannot override statutory limitation under section 153C.
The dispute arose from survey-based additions relying mainly on a statement and impounded agreement. The Tribunal held that the matter needed fresh examination and remanded it to the AO with one final opportunity.
ITAT Surat struck down a 50% turnover-based income estimation, applying Section 44AD to compute actual presumptive profit at 8%. Key takeaway: AO cannot inflate income without legal basis.
he tribunal held that an appellate order based on an incorrect and reconstructed timeline of statutory notices is unsustainable. Errors in sequencing of notices strike at the root of jurisdiction and require fresh adjudication.
The tribunal held that when the assessment order is remanded for de-novo adjudication, the very basis for penalty ceases to exist. Consequently, penalty proceedings under section 271(1)(c) become unsustainable.
The Tribunal held that when purchases are conclusively proved to be sham accommodation entries, the entire amount is disallowable under section 69C. Mere invoices and bank payments cannot override incriminating search evidence and admissions.
The tribunal ruled that a penalty under section 271(1)(c) cannot stand when the quantum addition forming its basis is deleted. The key takeaway is that penalty proceedings automatically fail without a surviving assessment addition.
