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...
Karnataka High Court sets aside ₹45 lakh Sec 69 addition, remands to ITAT to consider fresh evidence on property transaction and refund; holds explanation must be examined even at later stage.
The Tribunal held that the Assessing Officer cannot examine issues beyond the scope of limited scrutiny without approval. Since total deposits were assessed instead of only demonetization deposits, the addition was invalid and deleted.
The Tribunal deleted additions where the Revenue failed to prove actual cash transactions. It emphasized that suspicion and assumptions cannot replace evidence. The ruling protects taxpayers from arbitrary additions.
The Tribunal held that strict correlation between withdrawals and deposits is not required under Section 69. It ruled that reasonable cash availability and explanation based on probabilities is sufficient.
The issue was whether a notice granting less than the statutory minimum time is valid. The tribunal held that giving less than 7 days violates mandatory provisions, rendering the notice and entire reassessment proceedings invalid.
The issue was whether protective addition can survive when income is already taxed elsewhere. ITAT held that once income attains finality in another assessee’s case, protective addition cannot be sustained.
The Tribunal held that the CIT(A) improperly admitted additional evidence without satisfying Rule 46A conditions or recording reasons. It emphasized that procedural compliance is mandatory and failure to follow it invalidates the relief granted.*
The Tribunal held that additions based solely on third-party statements and Excel sheets are unsustainable without independent evidence. It emphasized that denial of cross-examination violates natural justice and invalidates the addition.
ITAT Mumbai deletes Section 69 additions holding that third-party excel sheets and statements without corroborative evidence lack evidentiary value. Reopening based on unverified data and denial of cross-examination violates natural justice; entire additions quashed.
Addition under Section 68 could not be sustained where assessee has established the genuineness of a Non-banking financial company (NBFC) investor, and the AO failed to rebut such evidence or trace any money trail linking the assessee to the invested funds.
