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 : The Tribunal held that disallowance of interest cannot be finalized when the validity of underlying loans is still under appeal. I...
Income Tax : The issue was whether purchases could be treated as bogus based on investigation reports. ITAT held that when documentary evidence...
Income Tax : The Tribunal held that purchases cannot be treated as bogus when supported by invoices, bank payments, and GST records. It ruled t...
Income Tax : The issue was whether income from hybrid seed production on leased land qualifies as agricultural income. The Tribunal held that o...
Income Tax : The issue was whether reassessment is valid without proper service of notice. The Tribunal held that absence of valid service make...
Additions under Sections 68 and 69C were set aside after the Tribunal found the mandatory approval to be a mere formality. The ruling reinforces that Section 153D approval is not a procedural ritual.
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.
