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 an unsigned and undated draft agreement seized from a third party cannot justify an addition for unexplained investment without corroborative evidence.
The Tribunal held that excess stock found during survey, when arising from regular business activity and disclosed in accounts, cannot be taxed as unexplained investment under Section 69B.
The dispute involved taxing a foreign investment as unexplained income. The Tribunal clarified that Section 69 applies only where investments are not recorded in books or the source remains unexplained.
The tribunal held that invoking Section 115BBE on survey-related excess stock was legally unsustainable for AY 2015-16. The addition was therefore liable to be taxed at normal rates.
ITAT Bangalore directs reassessment with full hearing for an agriculturist after procedural lapses in notices and missed hearings. The ruling emphasizes the importance of fair opportunity under Sections 148 and 144B.
Cash deposits were rightly taxed as unexplained money when the assessee failed to discharge the primary burden of proof. Absence of contemporaneous evidence defeats claims of redeposit of cash.
The Tribunal ruled that increasing assessed income without issuing a notice under section 251 violates natural justice. The case was remanded as ex-parte enhancement beyond the original addition was found legally unsustainable.
ITAT Bangalore invalidated a reassessment where the assessee was not provided the recorded reasons, emphasizing that reopening notices must be supported by clear, communicated reasons before filing returns.
The dispute centered on whether a reassessment notice was time-barred and sanctioned by the correct authority. The Tribunal held that the reply period under section 148A must be excluded, bringing the notice within three years and validating the sanction.
The Revenue argued for exclusion of the 148A show-cause period to justify approval. The Tribunal rejected this, holding that the exclusion proviso applies only prospectively from Finance Act 2023.
