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 : This guide explains how unexplained cash credits under Section 68 and related provisions can attract steep taxation under Section ...
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 : The ITAT Mumbai held that Section 69C cannot be invoked where expenditure is duly recorded in the books and its source is fully ex...
Income Tax : ITAT Guwahati held that additions could not be sustained where the transactions related to a separate partnership firm with a diff...
Income Tax : The ITAT held that an untested third-party statement, without supporting evidence or cross-examination, cannot form the sole basis...
Income Tax : ITAT Ahmedabad held that repayment of the entire loan with TDS-compliant interest payments undermined the allegation that the loan...
Income Tax : ITAT Chennai held that loose sheets and estimates alone cannot justify an addition under Section 69B without independent corrobora...
Income Tax : CBDT has instructed tax officers to uniformly apply Sections 68 to 69D and Section 115BBE after a C&AG audit found inconsistencies...
ITAT held that entire purchases cannot be disallowed when sales and stock are accepted. The addition was rightly restricted to 25% to cover possible inflation.
The Tribunal emphasized that without physical goods, exports and stock reconciliation would not be possible. Since quantitative records and gross profit remained consistent, the addition under Section 69C was deleted.
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.
