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 issue was whether a notice issued before filing of return satisfies Section 143(2) requirements. The Tribunal held such notice...
Income Tax : The issue was whether third-party diaries using code “DD” can justify 153C action. ITAT held that without clear identification...
Income Tax : The Tribunal held that additions cannot be sustained without incriminating material directly connecting the assessee to alleged ca...
Income Tax : The ruling clarified that unverified electronic records and third-party statements cannot justify additions without proper verific...
Income Tax : The Tribunal held reassessment invalid as the alleged escaped income did not exceed ₹50 lakh required for extended limitation. I...
It was held that applying Sections 69/69A read with Section 115BBE without examining penalty under Section 271AAC justified revision. The PCIT’s direction to reframe the assessment was sustained.
The Tribunal ruled that cash deposited during demonetisation came from genuine business sales already offered to tax. It held that taxing the same amount again under Section 68 and Section 115BBE would amount to impermissible double taxation.
The assessment was set aside as the Revenue produced no acknowledgment of service. The ruling reiterates that service of notice is foundational to reassessment.
The Tribunal held that wrist watches are valuable articles covered under Section 69A, and additions made under Section 69 were unsustainable.
The issue was whether a WhatsApp image from a third party could justify a cash addition. The Tribunal held the digital evidence inadmissible due to lack of lawful collection and chain of custody, deleting the addition.
The Tribunal followed binding High Court precedents to hold that reassessment must strictly adhere to the faceless mechanism. Deviation from the mandated procedure invalidated the notice and the entire reassessment.
The addition under Section 69 was remanded as the assessee claimed the source through rotation of funds. The Assessing Officer must now verify the fund flow after granting proper hearing.
The Tribunal examined whether unsecured loans could be treated as unexplained merely on investigation wing inputs. It held that once identity, creditworthiness, and genuineness are proved with documents, additions under Section 68 cannot survive.
The Tribunal ruled that unexplained investment additions based solely on a DVO report are invalid when books are not rejected and the report is not confronted to the assessee. The matter was remanded for fresh verification following natural justice.
The ruling clarifies that additions for unexplained investments cannot survive where credible evidence on source is later produced. The Tribunal restored the issue to the Assessing Officer to examine bank records and property sale proceeds.
