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...
ITAT held that section 249(4) cannot be invoked where no taxable income arises in India. Appeals must be decided on merits rather than dismissed on technical grounds.
ITAT Mumbai holds reassessment invalid where approval under Section 151 was obtained from incorrect authority, ruling defect as jurisdictional and quashing notice under Section 148 and consequent proceedings.
The Tribunal held that the Assessing Officer went beyond revisionary directions by including additional issues. It ruled that such excess additions were invalid and liable to be deleted.
The Tribunal dismissed the challenge to reassessment proceedings as no arguments were presented by the assessee. The ruling highlights that absence of pleadings can lead to automatic rejection of grounds.
ITAT confirmed validity of reassessment based on cash deposit information. However, it reduced addition by applying peak credit theory due to withdrawal patterns
The case examined whether documents found during search can be automatically attributed to the assessee. The Tribunal ruled that ownership and connection must be established through evidence. The decision underscores limits of statutory presumptions under Section 292C.
The issue was whether Section 153C could apply when the assessees own premises were searched. The tribunal held that such a person is a searched person, making Section 153A applicable instead. Consequently, assessments under Section 153C were quashed for multiple years.
Income without satisfactory explanation is taxed at a special high rate under Section 115BBE. The provisions place strict liability on taxpayers to justify the nature and source of funds.
The issue was whether disclosed investments could be treated as unexplained. The Tribunal held that Section 69 cannot be invoked when investments are recorded and taxed, upholding deletion of additions.
The case involved unexplained cash deposits during demonetization. The Tribunal upheld addition for unexplained shortage but deleted addition where advances were supported by evidence.
