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...
The issue was whether reassessment beyond three years was valid without approval from the correct authority. ITAT held the notice void as sanction was taken from the wrong officer, reaffirming strict compliance with Section 151.
The issue was whether cash and cheque payments could be taxed as unexplained investment in AY 2013–14. The Tribunal held that the major payments pertained to FY 2010–11 and could not be assessed in a later year.
The Tribunal examined whether a cash addition under section 69 could rest solely on an Excel sheet seized from a third party. It held the addition unsustainable due to lack of corroborative evidence and violation of natural justice.
The Tribunal held that additions for completed assessment years under section 153A are invalid when no incriminating material is found during search. Reliance on third-party documents and uncorroborated statements was held insufficient to sustain additions.
The Tribunal held that cash deposited in demonetised notes cannot be taxed under Section 69A when it represents recorded business sales. The key takeaway is that duly accounted turnover cannot be treated as unexplained merely due to demonetisation.
The ITAT held that additions based on survey material cannot be sustained without proper opportunity of hearing. The matter was remitted for fresh adjudication after finding violation of natural justice.
The tribunal examined whether gold jewellery seized during police interception could be taxed as unexplained solely based on a statement recorded under enquiry. It held that additions fail where later evidence shows the assessment relied on weak corroboration and inconsistent reasoning.
The appeals were rejected without examining additions made by the Assessing Officer. The Tribunal emphasized that appellate remedies cannot be defeated by procedural technicalities and restored the cases.
The Tribunal ruled that the reassessment was time-barred because limitation was wrongly computed from the search date. The key takeaway is that receipt of seized material governs jurisdiction for non-searched persons.
Gattula Lakshmi Madhavi Vs ACIT (ITAT Visakhapatnam) Central Circle Cannot Assume Reassessment Powers — Section 148 Notice Issued Outside Faceless Regime Held Void The Visakhapatnam Bench of the ITAT quashed the reassessment framed under Section 147 and consequential penalties under Sections 270A and 271AAC in the case of Gattula Lakshmi Madhavi v. ACIT, holding that […]
