Income Tax : Smt. Ranjana Kumari/Kalta Vs DCIT/ACIT (Central) (ITAT Chandigarh) The appeals involved three assessees belonging to the Kalta Gro...
Income Tax : This guide explains when penalties can be imposed under various provisions of the Income-tax Act, 1961. It also outlines the appli...
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 : ITAT Mumbai deleted a Section 69 addition after finding documentary evidence established joint ownership, source of funds, and ear...
Income Tax : ITAT held that a registered sale deed without corroborative evidence is not incriminating material and cannot support additions in...
Income Tax : ITAT held that multiplying a seized figure without supporting evidence was unjustified and restricted the Section 69 addition to t...
Income Tax : The Tribunal ruled that proceedings initiated under the old Section 153C framework after the Finance Act, 2021 amendments were leg...
Income Tax : Tribunal held that omission to mention the exact charging provision did not vitiate the assessment where unexplained cash and bull...
The ruling addressed conflicts between documentary proof of loans and third-party allegations of accommodation entries. The Tribunal held that unsupported allegations cannot override evidence establishing genuine loan transactions.
This covers how unexplained credits and investments are taxed under Sections 68 to 69D. The key takeaway is that additions require clear evidence and cannot rest on assumptions.
The Tribunal held that once business receipts are taxed on an estimated basis, separate additions for payments and assets from the same receipts are impermissible. Only a net-profit estimation was sustained, deleting multiple cascading additions.
The dispute involved taxing unexplained increases in partners capital in the firms assessment. The Tribunal affirmed that such additions, if any, can only be examined in the hands of partners and not the partnership firm.
The tribunal ruled that cash deposits sourced from recorded cash sales and bank withdrawals were genuine. It held that partial, ad-hoc additions without rejecting books of account are unsustainable.
Despite non-compliance during assessment, the Tribunal upheld deletion of additions where facts showed only renewal of deposits. Ex-parte proceedings do not justify treating old FDs as unexplained investments.
The Tribunal held that cash paid for a flat booking was explained through documented bank withdrawals. Unexplained investment addition was therefore deleted.
The Tribunal held that remanding an assessment under the amended section 251(1)(a) is legally valid. The key takeaway is that appellate remand powers now have clear statutory backing.
The court examined an assessment passed without considering the taxpayers detailed reply. It held that non-consideration of the reply violates natural justice, warranting remand.
The Tribunal ruled that when purchases are disallowed as non-genuine without questioning the source of payment, section 69C cannot be invoked. A plausible disallowance under section 37(1) cannot be revised under section 263 merely to change the charging provision.
