Income Tax : Indian tax law restricts cash transactions to promote digital payments. Limits apply to expense payments (Sec 40A(3): ₹10k/day),...
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 : Understand relief mechanisms and defences under Section 271D of the Income Tax Act for accepting cash loans or deposits over ₹20...
Income Tax : Supreme Court ruling on cash property deal cites wrong tax law (269ST instead of 269SS), but mandates reporting of large cash tra...
Income Tax : Simplified penalty timelines under Section 275 effective April 2025, including changes in penalty powers, omissions, and clarifica...
Income Tax : The Bombay High Court set aside a penalty order under Section 271-D after finding that the controversy was squarely covered by its...
Income Tax : ITAT Delhi held that the PCIT exceeded jurisdiction by introducing issues not mentioned in the Section 263 show-cause notice. The ...
Income Tax : ITAT Mumbai held that where reassessment is based on documents seized during a search on another person, proceedings must be initi...
Income Tax : ITAT Mumbai ruled that once reassessment proceedings are quashed as void ab initio, the satisfaction recorded therein for initiati...
Income Tax : The Bombay High Court held that penalty proceedings under Section 271-D cannot continue independently when the appeal against the ...
Income Tax : It is a settled position that period of limitation of penalty proceedings under section 271D and 271E of the Act is governed by th...
Income Tax : It has been brought to notice of CBDT that there are conflicting interpretations of various High Courts on the issue whether the l...
The Bombay High Court set aside a penalty order under Section 271-D after finding that the controversy was squarely covered by its earlier decisions. The Court followed established precedents and allowed the writ petition.
ITAT Delhi held that the PCIT exceeded jurisdiction by introducing issues not mentioned in the Section 263 show-cause notice. The revision order was quashed for travelling beyond the scope of the proceedings.
ITAT Mumbai held that where reassessment is based on documents seized during a search on another person, proceedings must be initiated under Section 153C and not Section 147.
ITAT Mumbai ruled that once reassessment proceedings are quashed as void ab initio, the satisfaction recorded therein for initiating penalty proceedings cannot survive independently. The Tribunal relied on the Supreme Court ruling in Jaya Lakshmi Rice Mills.
The Bombay High Court held that penalty proceedings under Section 271-D cannot continue independently when the appeal against the underlying assessment order is pending before CIT(A). The Court directed that the penalty proceedings remain in abeyance until the appellate proceedings conclude.
The Tribunal ruled that mere observations about cash transactions are insufficient to levy penalty under Section 271D. A specific finding establishing contravention of Section 269SS is mandatory before imposing penalty.
The Telangana High Court set aside a penalty under Section 271D after finding that the assessment order contained no recorded satisfaction for initiating penalty proceedings. The Court held that Supreme Court precedent on mandatory satisfaction was binding on tax authorities.
ITAT Kolkata set aside the penalty order under Section 271D after the assessee claimed inadequate opportunity of hearing during penalty proceedings. The matter was remanded for fresh adjudication and examination of supporting evidence.
The Court ruled that although the Joint Commissioner is the competent authority to levy penalty, initiation of proceedings still requires satisfaction recorded during assessment proceedings. Absence of such satisfaction rendered the penalty invalid.
The Gujarat High Court held that revisional powers under Section 263 cannot be invoked merely because the Commissioner prefers another valuation method. The Court ruled that the Assessing Officer had conducted proper inquiry and adopted a plausible view based on the DVO report.