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 : The Tribunal held that reliance on third-party statements without granting effective cross-examination amounted to a violation of ...
Income Tax : ITAT Mumbai held that an addition under Section 69A cannot be sustained when the assessee is denied the opportunity to cross-exami...
Income Tax : Income without satisfactory explanation is taxed at a special high rate under Section 115BBE. The provisions place strict liabilit...
Corporate Law : Details on Indian government's blocking of YouTube channels, citing IT Rules 2021 and Section 69A of IT Act 2000. Learn about reas...
Income Tax : ITAT Bangalore remanded a Section 69A addition after holding that an APMC commission agent's entire sale proceeds could not be tre...
Income Tax : ITAT Bangalore deleted the Section 69A addition after holding that member details established the source of cash deposits made dur...
Income Tax : ITAT held that negative cash balances do not automatically establish undisclosed income and upheld addition only to the peak negat...
Income Tax : ITAT held that penalty under Section 271D cannot survive where the Assessing Officer failed to record satisfaction in the assessme...
Income Tax : ITAT Allahabad held that estimating gross profit solely on the basis of the subsequent years GP rate is not justified after reject...
Income Tax : CBDT has instructed tax officers to uniformly apply Sections 68 to 69D and Section 115BBE after a C&AG audit found inconsistencies...
The ITAT held that issuance of Section 148 notice by a Jurisdictional Assessing Officer instead of a Faceless Assessing Officer violates Section 151A, leading to quashing of the reassessment.
Detailed seized agreement and subsequent sale deed considered strong corroboration. Addition under Section 69A sustained in search-based reassessment.
Tribunal held that ownership records alone cannot justify agricultural income; absence of Khasra and produce-sale evidence required remand. Cultivation must be proved with proper documentation.
ITAT remanded assessment where substantial 69A addition was made without giving the assessee a chance to present his case. Procedural fairness is critical, even in non-filing scenarios.
The tax authority’s assessment and penalty were set aside as the assessee was not given a fair opportunity to submit documents or Rule 46A application. The court emphasized adherence to natural justice before rejecting section 54F claims.
The Tribunal held that unexplained money addition cannot stand when the AO ignores direct verification from the bank. Matter restored to the AO to summon the bank and tax only actual interest income.
The Tribunal found that a fixed-deposit mismatch caused an unjustified ₹5.33-crore addition. Delay was condoned and the matter was remanded for fresh assessment with proper verification.
The Revenue relied on third-party statements and WhatsApp data to allege an unrecorded ₹25 crore cash loan, but brought no supporting inquiry or cross-examination. The Tribunal held that the AO’s conclusion was speculative, especially when bank-backed evidence, TDS records, and a registered loan agreement supported only a ₹10 crore loan. Key takeaway: additions under Section 69A require concrete evidence, not assumptions.
The Tribunal ruled that the seized notes clearly connected the assessee to both the loan and property investment, validating jurisdiction under Section 153C. The assessee’s failure to submit any proof led to confirmation of the additions. The case highlights the importance of evidence-based rebuttal in search-related assessments.
The Tribunal held that the Section 148 notice issued by the jurisdictional officer instead of the faceless authority violated Section 151A. With the notice invalid, the reassessment and jewellery addition were quashed.
