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 Chandigarh held that reassessment proceedings were invalid because the Assessing Officer recorded incorrect facts regarding the return filing date and declared income. The Tribunal ruled that such defective reasons could not support a valid belief of escaped income.
The Tribunal held that once immunity under Section 270AA was granted and the assessee accepted the assessment without appeal, the Assessing Officer could not later alter the assessment through Section 154 rectification. The ruling reinforces the finality and certainty intended by the immunity scheme.
ITAT Delhi held that high sea sales could not be treated as non-genuine where customs approvals, sale agreements, and delivery records established the transactions. The Tribunal deleted the ₹59.11 crore addition and ruled that Section 68 could not apply to recovery of sale consideration.
Assessments arising from searches conducted after 01.04.2021 must strictly comply with the reassessment framework under sections 147 and 148. Failure to adhere to statutory jurisdictional requirements, including mandatory approvals and satisfaction for use of third-party material, rendered the entire assessment void.
CBDT has instructed tax officers to uniformly apply Sections 68 to 69D and Section 115BBE after a C&AG audit found inconsistencies in assessments and incorrect tax computations leading to revenue loss.
The ITAT held that once profit is estimated on unaccounted sales, separate additions for wages and operational expenditure cannot be made again under section 69C. The ruling treated such additions as double taxation of the same income stream.
The Tribunal condoned the delay in filing the appeal after finding that the assessee had no knowledge of the assessment proceedings due to missed email notices. The assessment was restored for de novo adjudication.
Chennai ITAT held that variations between Insight Portal data and GSTR-2A could not automatically establish unexplained expenditure under Section 69C. The Tribunal ruled that no addition could be sustained without evidence of actual unrecorded expenditure.
The Tribunal ruled that only 8% of disputed purchases could be added where the assessee had disclosed corresponding sales and made payments through banking channels. Entire purchase disallowance was held to distort true business income.
Mumbai ITAT held that granting only seven days for compliance before dismissing an appeal violates principles of natural justice. The Tribunal restored the Section 69C addition matter for fresh adjudication after finding inadequate hearing opportunity.
