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...
The issue involved addition under Section 69A for demonetization cash deposits. The Tribunal held that once sale consideration was accepted as source, the addition could not be sustained.
The tribunal ruled that unverified claims of cash payments based on third-party material cannot justify tax additions. It emphasized that evidence must directly implicate the taxpayer.
The Tribunal held the assessment invalid as no mandatory notice under Section 143(2) was issued. The key takeaway is that absence of such notice renders the entire assessment void.
The Tribunal examined whether demonetisation cash deposits linked to recorded business sales could be taxed as unexplained income. It ruled that once the source is established through books, addition under Section 68 is unsustainable.
The issue involved additions for alleged cash payments based on third-party data and statements. ITAT deleted the additions, holding that no independent evidence or cross-examination opportunity was provided.
The court held that reassessment notices for A.Y. 2015–16 issued after 1 April 2021 are invalid based on the Revenue’s concession before the Supreme Court. All consequential proceedings were set aside.
The issue was whether reassessment under Section 147 is valid after a search. The ITAT held it invalid, ruling that only Section 153A applies post-search, making the reassessment void.
With the reassessment proceedings held invalid, additions relating to property valuation and unexplained investment were not examined on merits. The appeal was allowed on legal grounds.
The Tribunal ruled that additions under Section 69 cannot be sustained when based solely on third-party statements and unverified electronic data. It emphasized the absence of independent evidence and upheld the taxpayers denial of cash payments.
The issue was whether rejection of books and GP estimation was justified due to missing records. ITAT upheld the addition, ruling that failure to produce bills, vouchers, and stock records justified estimation.
