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 Mumbai deleted Sec 69 addition for alleged on-money, holding third-party statements and pen-drive data without cross-examination or corroboration are invalid evidence.
The alleged unexplained investment was based only on third-party statements and seized digital data. In absence of receipts, confirmations, or admission by the assessee, the addition of ₹50 lakh was deleted.
The addition under Section 68 was deleted as capital introduced by partners is not a loan or unexplained credit of the firm. Enquiry into partners creditworthiness must be conducted separately in their cases.
The Tribunal held that alleged on-money addition based solely on third-party loose papers is unsustainable. In absence of independent evidence linking the assessee to unaccounted payment, the addition was deleted.
ITAT held that once identity, genuineness and creditworthiness of the loan creditor were established, addition under Section 69 was unsustainable. The creditors disclosure before the Settlement Commission supported the assessee’s claim.
ITAT held that Excel sheets recovered from a third party cannot justify addition without direct evidence linking the assessee. In absence of corroboration and cross-examination, the cash investment addition was deleted.
The Tribunal confirmed that once identity, source, and movement of funds are established through records, treating the investment as unexplained is unjustified. Revenues appeal was dismissed.
The Tribunal clarified that even where the assessee owns more than ten trucks, Section 44AE can be used as a fair yardstick for income estimation. Arbitrary assessment and multiple additions were set aside.
The Tribunal ruled that incorrect computation of opening and closing stock during survey cannot justify full addition. Only the reconciled excess stock amount already offered to tax was sustained.
The Tribunal held that additions under Section 69 cannot be sustained when based solely on third-party statements and unverified electronic data without independent corroboration or cross-examination.
