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 Agra ITAT held that an independent addition under Section 69A was unsustainable when the AO had accepted the assessee’s declared business income. The Tribunal directed reconsideration of the deposits after evaluating the business receipts.
The ITAT held that a penalty under Section 271AAC could not be decided independently when the underlying assessment had already been remanded for fresh adjudication. The penalty issue was restored to the AO for reconsideration after completion of quantum proceedings.
The ITAT Chennai ruled that funds received by a Chartered Accountant for remitting clients’ taxes could not be treated as unexplained money. Documentary evidence showing corresponding tax payments led to deletion of the additions.
The ITAT Delhi held that cash deposits during the demonetization period could not be treated as unexplained credits when they originated from duly recorded business sales accepted by the Revenue. The Tribunal upheld deletion of the addition under Section 68.
Delhi ITAT held that assessments under Section 153C were invalid where the satisfaction note for the non-searched person was recorded after 01.04.2021. The Tribunal ruled that Section 153C(3) barred such proceedings, rendering the assessments void.
The ruling emphasizes that undisclosed business receipts and stock arising from an existing business cannot automatically be characterized as unexplained income. In the absence of evidence pointing to any other source, the income should be assessed under normal business provisions.
Addition of ₹90 lakh made under section 69A towards alleged cash payment for purchase of property as well as the addition made under section 69C on account of alleged unaccounted purchases was deleted as additions based solely on third-party documents, without independent corroboration or evidence directly linking the transactions to assessee were not sustainable in law.
The Court held that the assessee failed to produce any written or registered document proving transfer of property to the firm. Consequently, the challenge to the assessment proceedings was rejected, leaving the assessee to pursue statutory appellate remedies.
The Tribunal accepted that part of the cash found with the assessee represented accumulated family savings intended for the medical treatment of his wife suffering from cancer. It granted relief of ₹12 lakh and sustained only ₹7.79 lakh as unexplained income.
The Tribunal held that delay in filing appeals was justified where the assessee had shifted to a new PAN and filed returns under it. The matter was remanded to the CIT(A) for fresh consideration.
