Supreme Court rules 2015 amendment to Income Tax Act’s Section 153C, broadening third-party assessment, is not retrospective; applies only to searches after June 1, 2015.
The Supreme Court clarifies that the six-year tax assessment period for third parties, whose documents are seized, starts from the date their AO receives materials, not the original search date.
ITAT Mumbai rules in favor of JM Financial Properties, upholding interest expense deductions for AY 2013-14 and 2014-15. The tribunal affirmed the commercial expediency of an interest-free security deposit for business purposes.
ITAT Nagpur voids reassessment against Rupesh Dhakate, citing lack of jurisdiction as alleged escaped income fell below the Rs. 50 lakh threshold.
Subsequently, the petitioner submitted a representation/application dated 05.09.2024 and 24.10.2024 seeking the respondents for the refund of the adjust amount along with interest for which the petitioner neither received a reply nor the refund.
Delhi High Court held that prior approval u/s. 151 for issuance of notice under section 148 of the Income Tax Act beyond period of three years mandatory even in case of extended limitation under TOLA. Accordingly, notice and order thereon set aside.
ITAT Hyderabad held that adhoc disallowance under section 40A(2)(a) of the Income Tax Act merely on the basis of suspicion and surmises without adequate evidence not sustainable in law. Accordingly, order of CIT(A) upheld and appeal of revenue dismissed.
As discussed above amendment and assessment/re-assessment signify two clearly distinct connotations importing distinct and separate meanings and encompassing different areas of action. We are thus not able to appreciate any merit in the view as canvassed by the Ld. Counsel.
ITAT Nagpur rules against arbitrary 10% cash deposit addition under Section 69A, stating no income can be deemed if explanations are credible.
Delhi High Court held that penalty imposed under section 276B of the Income Tax Act is liable to be set aside on account of section 278AA of the Income Tax Act as reasonable cause shown. Accordingly, petition by revenue dismissed.
