Income Tax : ITAT held that additions based solely on third-party search material without independent evidence or cross-examination are invalid...
Income Tax : Income without satisfactory explanation is taxed at a special high rate under Section 115BBE. The provisions place strict liabilit...
Income Tax : A doctrinal analysis of unexplained cash credits, investments, and expenditure under Sections 68–69D. Explains burden of proof a...
Income Tax : This covers how unexplained credits and investments are taxed under Sections 68 to 69D. The key takeaway is that additions require...
Income Tax : ITAT held that section 69 cannot be invoked where purchases are duly recorded in books and paid through banking channels, making t...
Income Tax : The ITAT Amritsar held that a valuation report by itself cannot justify addition under Section 69 without evidence of extra paymen...
Income Tax : The ITAT held that stamp duty valuation could not be blindly adopted where the property was affected by BBMP demolition proceeding...
Income Tax : The ITAT Delhi upheld deletion of a Rs.6 crore addition under Section 68 after finding that the share sale transactions were prope...
Income Tax : Delhi ITAT held that investments in immovable properties cannot be treated as unexplained once payments are made through disclosed...
Income Tax : The Tribunal held that entries found in third-party ERP software during a search cannot alone justify unexplained investment addit...
The ITAT Amritsar held that a valuation report by itself cannot justify addition under Section 69 without evidence of extra payment. The Tribunal deleted the addition after finding no proof of on-money beyond the registered sale deed value.
The ITAT held that stamp duty valuation could not be blindly adopted where the property was affected by BBMP demolition proceedings for unauthorized construction. The Tribunal accepted the actual purchase price as fair market value and deleted the addition.
The ITAT Delhi upheld deletion of a Rs.6 crore addition under Section 68 after finding that the share sale transactions were properly documented and routed through banking channels. The Tribunal held that the Assessing Officer failed to prove that the transactions represented unaccounted income.
Delhi ITAT held that investments in immovable properties cannot be treated as unexplained once payments are made through disclosed bank accounts with explained credits. The Tribunal deleted ₹3.29 crore addition for lack of incriminating material.
The Tribunal held that entries found in third-party ERP software during a search cannot alone justify unexplained investment additions under Section 69. Absence of corroborative evidence led to deletion of the entire addition.
The Tribunal held that reassessment proceedings were invalid where the Assessing Officer ignored the assessees detailed response and documentary evidence. ITAT ruled that such action violated principles of natural justice and reflected non-application of mind.
The Tribunal held that merely declaring presumptive income under Section 44AD does not exempt taxpayers from explaining massive bank credits. In absence of purchase records, bills, or confirmations, Section 69A addition was sustained.
ITAT Ahmedabad held that no unexplained investment addition could survive where the booked property deal was cancelled and funds were refunded. The ruling emphasized verification of actual payment flow and subsequent cancellation events.
The Tribunal held that validity of reopening under Section 148 must be tested on the basis of material available when reassessment proceedings are initiated. Subsequent reduction in additions does not invalidate jurisdiction already assumed.
ITAT Delhi held that penalty under Section 271AAC cannot survive once the underlying Section 153C assessment is quashed. The Tribunal deleted the penalty after noting that the quantum assessment itself no longer existed.
