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...
ITAT Ahmedabad held that a section 263 revision cannot proceed if the AO issuing section 148 notice lacks territorial jurisdiction, emphasizing the need to first decide jurisdictional validity.
The Income Tax authorities treated LTCG from Kappac Pharma shares as unexplained cash credit. The Tribunal confirmed the transactions were genuine, supported by demat and broker records. The addition under Section 68 and related commission expenses were deleted.
ITAT held that cash deposits made by directors before investing in share capital cannot be treated as unexplained income of the company. The ruling emphasizes that proper identity, creditworthiness, and genuineness documentation must be evaluated before invoking Section 68.
The Tribunal ruled that unexplained investment cannot be added without confronting the assessee with the Koinex transaction data relied upon by the AO. Matter remanded for fresh verification.
The Tribunal held that once the High Court had already quashed the original assessment for violating the IBC resolution plan, the PCIT’s section 263 revision could not survive. Since a revision must rest on a valid assessment order, the entire 263 action became void. The appeals were allowed and the revision orders were cancelled.
ITAT held that Section 69 cannot apply when the assessee is not proved to own the cash. Unrebutted affidavits established the source, and mere suspicion cannot justify an addition.
Tribunal held that an investment already assessed substantively in another person’s hands cannot again be taxed under Section 69. The case was remanded to avoid double taxation and ensure consistent adjudication.
The Tribunal ruled that Section 68 additions cannot apply when a company maintains no books of account, deleting ₹51 lakh and ₹1.25 crore additions. Confirms that technical defaults cannot override proper accounting requirements.
The Tribunal found that the Section 148 notice appeared on the portal after 31.03.2021, raising doubts about its validity. The matter was restored to CIT(A)/NFAC for fresh consideration, allowing the assessee to submit explanations. The ruling underscores strict compliance with notice issuance requirements under Section 148.
Rakesh Arora Vs ITO (ITAT Delhi) When the Reason Falls, the Case Falls: Rs. 3.14 Cr Trigger Proves False — ITAT Delhi Quashes Whole 147 The reassessment for AY 2012–13 was triggered solely on the allegation that the assessee had received accommodation entries of ₹3,14,16,000 from M/s Shreyas International. However, at the time of completing […]
