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 tribunal ruled that statements of third parties cannot be relied upon unless the assessee is provided copies and allowed cross-examination. Denial of this right renders the additions legally untenable.
The Tribunal confirmed deletion of additions where the AO made no effort to verify consignees, transporters, or stock movement. Proper documentation and bank-received sale proceeds proved transaction genuineness.
ITAT Ahmedabad held that addition made on the basis of third-party WhatsApp chat without any incriminating material is unsustainable in law. Accordingly, order of CIT(A) upheld and appeal of revenue is dismissed.
The Tribunal held that when an eligible assessee fails to file objections before the DRP within time, a direct appeal to the Tribunal is barred. Non-compliance with section 144C renders the appeal non-maintainable.
The ruling emphasizes that statements relied upon by the Revenue must be confronted to the assessee with an opportunity of cross-examination. Failure to do so renders additions legally unsustainable.
The Tribunal noted that no construction investment occurred during the year under appeal. Accordingly, no addition for unexplained investment could be sustained in that assessment year.
Silkina Commodeal Pvt. Ltd. Vs ITO (ITAT Kolkata) ITAT Kolkata Deletes ₹21.39 Cr Section 68 Addition—Share Capital & Premium Cannot Be Added Solely for Non-Appearance of Investors The Kolkata Bench of the ITAT allowed the appeal of Silkina Commodeal Pvt. Ltd. for AY 2008-09 and deleted the addition of ₹21.39 crore made under section 68 […]
The case examined additions made in Section 153C assessments based on third-party search material. The Tribunal ruled that additions cannot stand unless incriminating documents are furnished to the assessee.
The issue was whether reassessment can proceed without furnishing recorded reasons despite a taxpayers request. The Tribunal held that failure to supply reasons is a jurisdictional defect that invalidates reassessment.
The issue was whether a recorded share investment can be treated as unexplained under Section 69. The Tribunal held that once an investment is recorded in the books and its source is not doubted, Section 69 cannot be invoked.
