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 reopening beyond six years is invalid without a recorded satisfaction of undisclosed assets exceeding ₹50 lakh. The takeaway is strict compliance with the fourth proviso to section 153A is mandatory.
The penalty was levied solely on the basis of an alleged unexplained investment under Section 69. Since the quantum addition was fully deleted, the Tribunal ruled that the penalty automatically collapses.
It was held that documented capital contributions supported by affidavits, bank records, and land evidence are explained credits. Assessing authorities cannot disregard undisputed financial capacity.
The issue was whether entire cash deposits and unsecured loans could be taxed as unexplained income. The Tribunal held that only the embedded profit is taxable and restricted the addition to 10%.
It was held that applying Sections 69/69A read with Section 115BBE without examining penalty under Section 271AAC justified revision. The PCIT’s direction to reframe the assessment was sustained.
The Tribunal ruled that cash deposited during demonetisation came from genuine business sales already offered to tax. It held that taxing the same amount again under Section 68 and Section 115BBE would amount to impermissible double taxation.
The assessment was set aside as the Revenue produced no acknowledgment of service. The ruling reiterates that service of notice is foundational to reassessment.
The Tribunal held that wrist watches are valuable articles covered under Section 69A, and additions made under Section 69 were unsustainable.
The issue was whether a WhatsApp image from a third party could justify a cash addition. The Tribunal held the digital evidence inadmissible due to lack of lawful collection and chain of custody, deleting the addition.
The Tribunal followed binding High Court precedents to hold that reassessment must strictly adhere to the faceless mechanism. Deviation from the mandated procedure invalidated the notice and the entire reassessment.
