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...
It was ruled that deciding appeals based on facts of another year is a serious legal error. The matter was sent back for reconsideration on correct facts.
The Tribunal held that absence of evidence beyond one month bars estimation for the full year. Only the amount directly supported by survey material can be taxed.
The issue was whether 100% of alleged bogus purchases could be disallowed despite accepted production and sales. The Tribunal held that only the embedded profit element can be taxed, not the entire purchase value.
Where the extent of inflated purchases cannot be quantified and is restricted to a nominal percentage, penalty provisions do not apply. The ruling reinforces the distinction between estimated additions and proven concealment.
The issue was whether the entire purchase amount could be added under Section 69C based solely on an entry-operator’s denial. The Tribunal ruled that since sales were accepted and books not rejected, only a 10% estimated disallowance was justified.
The issue was whether the entire amount of alleged bogus purchases could be disallowed under Section 69C. ITAT Mumbai held that in the absence of corroborative evidence, only the profit element can be taxed, restricting the addition to 6%.
This ruling clarifies that repayment of loan with interest, coupled with documentary proof, negates allegations of unexplained cash credit. Mere suspicion without defects in evidence cannot sustain an addition.
The Tribunal ruled that purchases cannot be treated as bogus merely because suppliers did not reply to Section 133(6) notices. When books are audited, evidence is produced, and sales are accepted, disallowance under Section 69C is unsustainable.
Alleged additions for suppressed sales, disallowances, and capital gains were rendered void once the revision order was quashed. The case underscores the doctrine of consequential invalidity.
The Tribunal held that reassessment was invalid as the statutory sanction under Section 151 was granted mechanically. Mere use of the word Approved does not show application of mind and vitiates the entire proceedings.
