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 Chennai held that Compulsorily Convertible Debentures retain the character of debt until conversion into equity. It ruled that interest on CCDs is deductible and that the TPO could not recharacterise them as equity.
ITAT ruled that the reassessment order passed under Section 147 was unsustainable as it exceeded the limitation period prescribed by the Income-tax Act. The decision highlights that statutory timelines cannot be ignored without supporting evidence from the Revenue.
ITAT Bangalore held that a ₹5 lakh investment could not be treated as unexplained under Section 69 where documentary evidence showed it was made through a cheque issued by the tenant under a lease arrangement.
ITAT Hyderabad held that an addition under Section 69 cannot be sustained solely on the basis of an uncorroborated loose sheet. The Tribunal ruled that independent evidence is necessary to establish alleged on-money payments.
The ITAT Mumbai held that where additions were based on seized material from a third-party search, proceedings should have been initiated under Section 153C and not Section 147. The assessment was declared invalid.
The ITAT held that Section 69A could not be invoked as the director was not the owner of the unaccounted cash generated through over-invoicing. The Tribunal upheld deletion of the addition while affirming that the company owned the cash.
The ITAT Mumbai restored the matter to the Assessing Officer after noting that the assessee had not explained the source of investments in deposits and foreign currency purchases. Fresh adjudication was directed after granting a reasonable opportunity of hearing.
The Tribunal ruled that Section 153C requires the AO of the other person to independently assess whether seized documents have a bearing on that person’s income. A mechanical satisfaction note based solely on another officer’s communication was held invalid.
The Tribunal ruled that third-party WhatsApp messages and decoded chat entries lacked evidentiary value against the assessee without corroborative material. The Revenue failed to prove that any cash was actually paid over and above the registered sale consideration.
The Tribunal condoned the delayed appeal filing after finding sufficient cause and allowed the matter to proceed. It also clarified that reassessment jurisdiction remains valid despite arguments regarding faceless assessment provisions.
