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...
Tribunal held that additions made solely on ex-parte proceedings cannot stand when the taxpayer was unable to comply due to age-related limitations. The case was remanded for fresh assessment with a direction to provide proper opportunity.
ITAT held that reassessment notices under sections 147/148 were invalid as the reasons were vague and lacked tangible evidence. Reopening cannot be used merely to verify or scrutinize transactions without proper justification.
ITAT held that additions based on an unsigned, unverified Excel sheet from a third party lacked evidentiary value. The reassessment was quashed as the assessee provided independent evidence disproving alleged on-money payments.
The Tribunal allowed the assessee’s claim under Section 44AD, recognizing the small kirana shop’s sales and deposits as genuine business income. Bank deposits corresponded with daily sales, and withdrawals matched purchase requirements, showing a consistent business pattern.
Additions for alleged on-money payments were disallowed because the evidence relied on by authorities contained errors and lacked authenticity. The decision highlights the need for corroborated, primary evidence in tax proceedings.
Tribunal remanded the case to the AO to reassess ULIP maturity receipts treated as unexplained investment after the exemption claim was not evaluated earlier.
ITAT Jaipur held that addition made on the basis of documents found from the third party without providing any opportunity of cross-examination is liable to be deleted on the ground of violation of principles of natural justice.
The Tribunal held that the appellate authority failed to pass a reasoned order under Section 250(6) and remanded the case for fresh consideration, directing that proper opportunity be given to the assessee.
The Tribunal found that the authorities mechanically endorsed a factually incorrect premise, resulting in an unjustified DVO reference. Such a negligible 1.71% variation could not support an unexplained-investment addition under Section 69. Due to non-application of mind throughout the process, the 153A assessment was struck down entirely.
ITAT Chandigarh upheld CIT(A)’s order deleting AO’s additions on depreciation, excess stock, and gross profit, confirming machinery was in use and books were reliable.
