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 ITAT Delhi ruled that the CIT(A) cannot reclassify an addition under a different provision of the Income-tax Act without issuing a specific notice to the taxpayer. The decision reinforces the limits of appellate powers and upholds principles of natural justice.
The Delhi ITAT held that reassessment proceedings were invalid where the Assessing Officer made additions unrelated to the reasons initially recorded for reopening. The consequential penalty proceedings were also set aside.
The Delhi ITAT sustained the addition arising from the sale of listed shares after finding discrepancies in purchase records, including contradictory sale notes and payment receipts. The Tribunal held that the assessee failed to establish the genuineness of the underlying share transactions.
Mumbai ITAT held that additions under Section 69 cannot survive where transactions are reflected in broker records and the source of funds is explained. Mere Client Code Modification information, without supporting evidence of tax evasion, is insufficient for making additions.
ITAT Mumbai ruled that additions under Section 69 cannot be sustained merely on suspicion when the entire property investment is supported by documentary evidence. The Tribunal emphasized that conjectures cannot substitute proof.
The Tribunal held that an incomplete document recovered from an employee’s laptop could not justify an addition under Section 69 without supporting evidence. The absence of cross-examination and independent verification weighed against the Revenue.
The ruling emphasizes that undisclosed business receipts and stock arising from an existing business cannot automatically be characterized as unexplained income. In the absence of evidence pointing to any other source, the income should be assessed under normal business provisions.
Addition of ₹90 lakh made under section 69A towards alleged cash payment for purchase of property as well as the addition made under section 69C on account of alleged unaccounted purchases was deleted as additions based solely on third-party documents, without independent corroboration or evidence directly linking the transactions to assessee were not sustainable in law.
The Mumbai ITAT held that an addition under section 69 cannot survive when the Revenue fails to establish that the alleged investment was made during the assessment year in question. Documentary evidence showing the transaction belonged to an earlier year remained uncontroverted.
The Court held that the assessee failed to produce any written or registered document proving transfer of property to the firm. Consequently, the challenge to the assessment proceedings was rejected, leaving the assessee to pursue statutory appellate remedies.
