Income Tax : Income without satisfactory explanation is taxed at a special high rate under Section 115BBE. The provisions place strict liabilit...
Income Tax : Courts have clarified that purchases cannot be disallowed without proper evidence. Genuine transactions supported by documents can...
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 : ITAT Hyderabad held that reassessment beyond three years was invalid as the Assessing Officer failed to demonstrate that the alleg...
Income Tax : The Tribunal deleted the addition after finding that the taxpayer had furnished complete documentary evidence of purchase and sale...
Income Tax : ITAT Delhi held that reassessment based solely on Investigation Wing reports without independent enquiry is invalid. The ruling em...
Income Tax : The Tribunal emphasized that once sales are entered in regular books and supported by stock records, the burden shifts to the Reve...
Income Tax : ITAT Mumbai held that additions under Sections 68 and 69C could not be sustained where the Revenue relied only on generalized inve...
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 Tribunal held that long-term capital gains could not be treated as bogus where documentary evidence supported the transactions and no material connected the assessee to price manipulation. The Revenue’s appeal was dismissed.
Despite voluminous documentation filed during assessment and appeal, the authorities concluded that no evidence was produced. The Tribunal found this approach grossly negligent and deleted the entire purchase addition.
ITAT ruled that without rejecting books of account or disproving sales, addition of aggregate cash deposits is unsustainable. Detailed reconciliations established nexus with business receipts.
The Tribunal deleted addition under Section 69C, holding that payments made by company on behalf of director were properly explained through ledger records and imprest arrangement.
The ITAT reaffirmed that Section 2(22)(e) cannot extend the definition of shareholder to a concern receiving the loan. The deemed dividend, if attracted, must be taxed in the hands of the substantial shareholder alone.
The AO added expenditure based solely on a mistaken audit report entry. The ITAT deleted the addition after confirming from the concerned party that no transaction occurred.
The Tribunal held that amounts reflected in regular books and disclosed in returns before search cannot be treated as unexplained expenditure. Section 69C was found inapplicable as no out-of-books spending was established.
The Tribunal emphasized that approval from the correct specified authority is mandatory where reopening exceeds three years. Failure to comply rendered the reassessment proceedings void ab initio.
The Tribunal held that assumption of jurisdiction under Section 153C was invalid due to a defective and consolidated satisfaction note. As the mandatory requirement of year-wise satisfaction was not met, the entire assessment was quashed.
The Tribunal held that failure to indicate the precise charge in a Section 274 notice renders penalty proceedings unsustainable. Following jurisdictional High Court rulings, the penalty was set aside.
