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...
ITAT Delhi held that recording a single satisfaction note for multiple assessment years violates Section 153C requirements. As no year-specific incriminating material was identified, the assessments were quashed along with the related penalty.
A doctrinal analysis of unexplained cash credits, investments, and expenditure under Sections 68–69D. Explains burden of proof and strict taxation under Section 115BBE.
The Tribunal upheld deletion of addition made on alleged unexplained investment in property. It held that difference between initial agreement value and final sale deed, without evidence of extra payment, cannot justify addition under Section 69.
ITAT Ahmedabad held that property payments were properly explained with bank records and affidavits. Additions under Section 69 for cash deposit and stamp duty were deleted.
The ITAT relied on orders under section 148A(d) for subsequent years where reopening was dropped, holding the assessee to be a local authority. The earlier additions for unexplained investment and interest income were set aside.
ITAT Mumbai deleted ₹6.15 lakh penny stock LTCG addition, holding investigation report and abnormal price rise insufficient without direct evidence linking assessee to accommodation entries.
Reassessment based solely on investigation inputs about penny stocks was rejected. The Tribunal held that documented transactions through bank and demat accounts sufficiently explained the investment source.
ITAT deleted ₹14.74 lakh addition as identical source was accepted in spouse’s case. Alleged on-money payment lacked corroborative evidence.
The Tribunal ruled that failure to issue notice under Section 143(2) after receiving return in reassessment proceedings is a jurisdictional defect. The reassessment order was quashed.
The ITAT Mumbai deleted the ₹14.70 lakh addition made under Section 69, holding that the NRI assessee had adequately explained the source of investment in property through documented overseas remittances routed partly via his mothers bank account.
