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 ITAT Raipur held that the assessee had already disclosed the sale of the old car in the return of income and paid tax on the profit from the transaction. Since the sale consideration and profit were recorded and taxed, the Tribunal noted that there was no loss to the Revenue.
The Delhi High Court upheld the ITAT s ruling that assessment orders were invalid because the approving authority granted Section 153D approval mechanically without examining the records.
The issue was whether the entire bank deposits could be treated as unexplained income under Section 69. The tribunal held that deposits linked to business activity cannot be fully taxed and directed estimation of profit at 8%.
The Tribunal held that entire bank deposits cannot automatically be treated as unexplained income under Section 69A. Instead, where deposits relate to commission-based transactions, only a reasonable profit percentage (2% of deposits) should be taxed.
The Tribunal held that cash deposits recorded in regular books of account cannot be treated as unexplained investments under section 69. Since the books were not rejected and no contrary evidence was produced, the addition was deleted.
The ITAT Chennai held that additions under Section 153A cannot be made for completed assessments when no incriminating material is found during search. Additions based only on special audit findings were therefore quashed.
The case addressed whether tax authorities can issue notices for multiple years based on one satisfaction note. The tribunal ruled that each assessment year requires an independent satisfaction linking seized material.
ITAT Pune held that creation of artificial intangible asset i.e. goodwill in intra-group merger is merely a colourable transaction out between the Holding Company and the subsidiary company. Accordingly, depreciation claimed thereon deserves to be disallowed.
The Tribunal ruled that exemption under Sections 11 and 12 cannot be denied by aggregating separate shareholdings to invoke Section 13(2)(e). It held that no office bearer individually held substantial interest, making the addition unsustainable.
The Tribunal upheld addition under Section 69 as the assessee failed to establish that the LIC investment belonged to the HUF. Mere assertion of agricultural income without documentary evidence was held insufficient.
