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 Tribunal ruled that unexplained investment additions cannot stand without concrete proof of actual investment. Mere survey information and assumptions do not shift the burden onto the taxpayer.
No incriminating material showed payment over the registered consideration. The tribunal held that without independent evidence, the ₹1.52 Cr addition could not be sustained.
The Tribunal held that a bona fide delay caused by genuine circumstances deserves condonation. The key takeaway is that technical limitation cannot override substantive justice.
The issue concerned massive additions made in an ex-parte assessment due to alleged unexplained share transactions. The Tribunal held that such issues require proper factual verification and remanded the case for fresh adjudication.
The Tribunal ruled that additions for alleged cash payments cannot survive when based solely on third-party statements and unverified electronic data. Absence of corroboration and denial of cross-examination violated principles of natural justice.
The ITAT Chennai held a reassessment notice under section 148 invalid as it was issued after the statutory limitation expired, emphasizing strict compliance with time limits.
The assessee neither filed returns nor responded to statutory notices, yet additions were deleted on appeal. ITAT held that absence of verification of source and compliance makes such deletion unsustainable.
The Revenue relied on alleged ₹4 crore unexplained investment to justify reopening beyond six years. The Tribunal ruled that even high-value allegations cannot override statutory limitation under section 153C.
Demonetisation-era jewellery sales were questioned as invoices mentioned buyers only as cash. The ITAT remanded the matter to verify buyer identity, stock linkage, and genuineness before sustaining any addition.
The dispute arose from survey-based additions relying mainly on a statement and impounded agreement. The Tribunal held that the matter needed fresh examination and remanded it to the AO with one final opportunity.
