Income Tax : This guide explains the penalty and prosecution framework under the Income-tax Act for AY 2026-27. It highlights the consequences ...
Income Tax : This FAQ serves as a reference for the Income-tax Act provisions relating to cash receipts, loans, repayments, and electronic paym...
Income Tax : The article explains how offences such as wilful tax evasion, failure to file returns, non-payment of TDS/TCS, falsification of re...
Income Tax : This article outlines major offences under the Income-tax Act that may result in prosecution, including tax evasion, non-payment o...
Income Tax : This article explains the statutory powers of the Principal Commissioner or Commissioner to waive or reduce penalties in genuine c...
Income Tax : ITAT held the Section 271D penalty was time-barred under Section 275(1)(c) as it was imposed after the prescribed limitation perio...
Income Tax : ITAT held that penalty under Section 271D cannot survive where the Assessing Officer failed to record satisfaction in the assessme...
Income Tax : ITAT held that penalty under Section 271D is invalid where the Assessing Officer failed to record satisfaction in the assessment o...
Income Tax : ITAT held that penalty under Section 271D cannot survive where the Assessing Officer failed to record satisfaction in the assessme...
Income Tax : Gujarat High Court upheld deletion of the Section 271D penalty, holding that absence of recorded satisfaction in the assessment or...
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 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.
ITAT Delhi held that levy of penalty under Section 271D requires pending or completed assessment proceedings containing findings on Section 269SS violation. Since no regular assessment was framed, the penalty was directed to be deleted.
The ITAT held that unverified third-party excel sheets without corroborative evidence cannot justify additions under Sections 69 or 69A. The Tribunal observed that mere electronic entries amount to dumb documents unless independently verified.
The ITAT ruled that penalty proceedings under Section 271D are invalid if the Assessing Officer fails to record satisfaction in assessment or related proceedings. Since no assessment proceedings existed in the case, the penalty was held unsustainable in law.
The Tribunal held that enhancement of income without issuing notice under section 251(2) is invalid. Such action violates principles of natural justice, leading to quashing of enhancement and related penalty directions.
The Tribunal held that Section 50C may not apply if properties are held as stock-in-trade. It remanded the case to verify whether transactions were part of real estate business.
