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 Delhi held that Section 69C cannot be invoked when purchases are recorded in books, paid through banking channels, and sources are explained. Estimated profit addition of 12.5% was deleted.
The Tribunal found that satisfaction under Section 153C was recorded long after the search and document transfer. Applying binding judicial precedent, ITAT ruled that the assessment was barred by limitation and therefore null and void.
The Tribunal upheld CIT(A)’s deletion of Rs. 10,00,059/- as the addition was based solely on uncorroborated third-party information. No primary evidence linked the assessee to the alleged accommodation entries.
The Tribunal deleted Rs. 26.73 lakhs added under Section 69A, holding that the deposit was from agricultural income and prior withdrawals. Revenue failed to disprove the assessee’s explanation, confirming that farmers’ cash deposits need proper evaluation.
The court ruled that once purchases are found unproved, restricting additions to a profit percentage is incorrect. Full disallowance is required under Section 69C where genuineness is not established.
The key question was whether STR-based information can trigger harsh taxation under Section 115BBE. The ITAT held that without concrete evidence of non-genuine transactions, such additions cannot stand. Both reopening and tax addition were annulled.
The Tribunal held that a Section 148 notice issued after three years was invalid because the escaped income was below ₹50 lakh, making the reopening beyond limitation.
ITAT Pune sent back the issue of alleged bogus purchases for A.Y. 2017-18, directing AO to examine GST closure letters, transportation evidence, and other supporting documents to determine genuineness.
The Tribunal quashed additions for bogus purchases, cash seizures, and transfer pricing adjustments, affirming the AOP’s unified management and correct taxation at the consortium level.
The Tribunal held that reopening under Section 147 was legally sound and unaffected by arguments based on 153C or Notification 18/2022. Still, it directed a full rehearing because the appellate authority issued non-speaking orders without examining the merits.
