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 : Detailed overview of penalties under various sections of the Income Tax Act, covering defaults in tax payment, reporting, document...
Income Tax : Delhi ITAT deleted a 69C unexplained expenditure addition for alleged bogus purchases, ruling that when corresponding sales are ac...
Income Tax : Interest under Section 234B cannot be levied on Section 115BBE-assessed income for resident senior citizens exempt from advance ta...
Income Tax : An overview of Sections 68-69D of India's Income-tax Act, which empower tax authorities to assess unaccounted income from unexplai...
Income Tax : The tribunal held that a purchase cannot be treated as bogus solely based on third-party allegations. Without independent verifica...
Income Tax : ITAT Mumbai held that protective additions under Sections 68 and 69C cannot survive once substantive additions are confirmed in th...
Income Tax : Additions based on survey-time valuation of machinery were deleted as the Assessing Officer had not rejected the books of account....
Income Tax : The ruling addressed conflicts between documentary proof of loans and third-party allegations of accommodation entries. The Tribun...
Income Tax : ITAT Chennai held that reassessment notice under section 148 of the Income Tax Act issued with approval of the Member of CBDT inst...
The tribunal held that a purchase cannot be treated as bogus solely based on third-party allegations. Without independent verification by the Assessing Officer, the disallowance was held unsustainable.
ITAT Mumbai held that protective additions under Sections 68 and 69C cannot survive once substantive additions are confirmed in the hands of beneficiaries. The ruling prevents double taxation of the same income and limits misuse of protective assessments.
Additions based on survey-time valuation of machinery were deleted as the Assessing Officer had not rejected the books of account. Prior binding orders in the same case were followed, reaffirming settled law.
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.
ITAT Chennai held that reassessment notice under section 148 of the Income Tax Act issued with approval of the Member of CBDT instead of Pr. CCIT is void and invalid. Accordingly, order passed under section 147 is without legal standing and hence quashed.
Reopenings based on assumptions, conjecture, or generalized allegations were struck down. The ruling reiterates that reasons must show tangible material, application of mind, and a live nexus with escaped income.
The Tribunal held that remanding an assessment under the amended section 251(1)(a) is legally valid. The key takeaway is that appellate remand powers now have clear statutory backing.
Construction, fit-out, and IT installation costs capitalised in fixed assets were held genuine. The Tribunal emphasized substance of records over suspicion based on third-party allegations.
Sales already offered to tax cannot be added again under section 68. With stock movement evidenced and books not rejected, treating recorded turnover as unexplained cash credit was held unsustainable.
The Tribunal held that remanding an assessment under the amended section 251(1)(a) is legally valid. The key takeaway is that appellate remand powers now have clear statutory backing.
