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 assessee neither filed returns nor responded to statutory notices, yet additions were deleted on appeal. ITAT held that absence of verification of source and compliance makes such deletion unsustainable.
The Revenue relied on alleged ₹4 crore unexplained investment to justify reopening beyond six years. The Tribunal ruled that even high-value allegations cannot override statutory limitation under section 153C.
Demonetisation-era jewellery sales were questioned as invoices mentioned buyers only as cash. The ITAT remanded the matter to verify buyer identity, stock linkage, and genuineness before sustaining any addition.
The dispute arose from survey-based additions relying mainly on a statement and impounded agreement. The Tribunal held that the matter needed fresh examination and remanded it to the AO with one final opportunity.
The Tribunal reaffirmed that satisfaction must be recorded contemporaneously or immediately after the searched person’s assessment. Any belated recording invalidates the assumption of jurisdiction under section 153C.
Mumbai ITAT upholds deletion of ₹70 lakh under Section 69, ruling that uncorroborated WhatsApp scribbles from a third party cannot establish unexplained cash income.
Applying a liberal approach, the tribunal condoned delay in appeal filing and examined the jurisdictional defect. Since reopening was initiated by the wrong authority, the assessment could not survive.
he tribunal held that reassessment notices issued by the jurisdictional assessing officer instead of the faceless authority violate the mandatory faceless assessment framework. Such jurisdictional defects render the entire reassessment proceedings void ab initio.
The Tribunal ruled that once an appeal is rejected as time-barred, the appellate authority cannot adjudicate it on merits. A contradictory approach violates jurisdictional discipline and warrants remand.
The Tribunal deleted on-money additions where the tax department failed to establish a clear nexus between the assessee and alleged cash entries. Suspicion or unverified third-party material was held insufficient in law.
