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 reaffirmed that satisfaction must be recorded contemporaneously or immediately after the searched person’s assessment. Any belated recording invalidates the assumption of jurisdiction under section 153C.
Mumbai ITAT upholds deletion of ₹70 lakh under Section 69, ruling that uncorroborated WhatsApp scribbles from a third party cannot establish unexplained cash income.
Applying a liberal approach, the tribunal condoned delay in appeal filing and examined the jurisdictional defect. Since reopening was initiated by the wrong authority, the assessment could not survive.
he tribunal held that reassessment notices issued by the jurisdictional assessing officer instead of the faceless authority violate the mandatory faceless assessment framework. Such jurisdictional defects render the entire reassessment proceedings void ab initio.
The Tribunal ruled that once an appeal is rejected as time-barred, the appellate authority cannot adjudicate it on merits. A contradictory approach violates jurisdictional discipline and warrants remand.
The Tribunal deleted on-money additions where the tax department failed to establish a clear nexus between the assessee and alleged cash entries. Suspicion or unverified third-party material was held insufficient in law.
The issue was whether reopening could be done when a jointly owned property exceeds ₹50 lakh in total value. The Tribunal held that only the assessee’s share counts; if it is below ₹50 lakh, reopening beyond three years is without jurisdiction.
The AO invoked Explanation 1(v) to section 153 to justify delay. The Tribunal clarified that an invalid 142A reference gives no such protection, rendering the order time-barred.
The Tribunal ruled that cash deposited from recorded demonetisation-period sales cannot be treated as unexplained when books and VAT turnover are accepted. Suspicion without evidence cannot justify section 69A additions.
Delhi High Court held that summons under section 70 of the Central Goods and Services Tax Act [CGST Act], is issued for gathering information and providing an opportunity to produce documents, it cannot be considered to be initiation of proceedings against the petitioner. Thus, writ dismissed as premature.
