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 Tribunal held that without any incriminating material belonging to the assessee found during search, proceedings under Section 153C are invalid. Addition based solely on third-party statements was set aside.
ITAT ruled that a 76/23 split in chats reflected proposed refurbishment costs, not undisclosed cash consideration. In absence of corroborative material, addition under Sections 69 and 115BBE was held unsustainable.
The Tribunal condoned a 298-day delay in filing appeal, holding that substantial justice must prevail over technicalities. It deleted additions on exempt gratuity and commuted pension, ruling they cannot be taxed as salary.
The Tribunal restored the matter after finding that the appellate authority failed to decide the assessees grounds on merits. The case was remanded for fresh adjudication with directions to consider all documents.
Summons under Section 70 of the CGST Act was only a step in the process of inquiry. Mere issuance of summons could not be equated with arrest or initiation of recovery proceedings.
The ITAT ruled that once the assessee establishes the source of investment, addition for unexplained investment cannot survive. Direct payment by a financier through demand draft explained the transaction.
The ruling addressed conflicts between documentary proof of loans and third-party allegations of accommodation entries. The Tribunal held that unsupported allegations cannot override evidence establishing genuine loan transactions.
This covers how unexplained credits and investments are taxed under Sections 68 to 69D. The key takeaway is that additions require clear evidence and cannot rest on assumptions.
The Tribunal held that once business receipts are taxed on an estimated basis, separate additions for payments and assets from the same receipts are impermissible. Only a net-profit estimation was sustained, deleting multiple cascading additions.
The dispute involved taxing unexplained increases in partners capital in the firms assessment. The Tribunal affirmed that such additions, if any, can only be examined in the hands of partners and not the partnership firm.
