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Judiciary

Recording of consolidated satisfaction note u/s. 153C for different assessment years is bad-in-law

April 5, 2025 1458 Views 0 comment Print

ITAT Pune held that satisfaction note is required to be recorded u/s.153C for each assessment year, thus, recording of consolidated satisfaction note for different assessment years (AY) would vitiate the entire assessment proceedings.

Addition towards undisclosed income sustained as incriminating material found during search not explained

April 5, 2025 531 Views 0 comment Print

ITAT Jaipur held that addition towards undisclosed income rightly sustained since assessee failed to explain the incriminating material found during the course of search. Penalty under section 271AAB too sustained.

Rejection of registration application is justified if the assessee fails to provide necessary details

April 5, 2025 762 Views 0 comment Print

ITAT Raipur held that application for registration u/s. 12A(1)(ac)(iii) of the Income Tax Act rightly rejected since assessee, without any justifiable reason, failed to provide requisite details/ documents specifically called by CIT(E).

Addition of income which has escaped assessment sustained even if not specifically mentioned in re-opening order

April 5, 2025 732 Views 0 comment Print

Guwahati High Court held that AO can make addition of any other income which has escaped assessment but discovered during re-opening process even if the same is not specifically mentioned in re-opening order.

CIT(E) cannot reject application for registration u/s. 80G(5)(iii) in hyper technical manner

April 5, 2025 654 Views 0 comment Print

ITAT Delhi held that CIT(E) has rejected application for registration u/s. 80G(5)(iii) of the Income Tax Act without giving cogent reason by disposing the matter in hyper technical manner without discussing on merits is not tenable in law.

Notice not stating specific limb of Sec. 271(1)(c) cannot be sustained: ITAT Raipur

April 5, 2025 1407 Views 0 comment Print

ITAT Raipur held that penalty u/s. 271(1)(c) of the Income Tax Act is liable to be struck down for the failure on the part of the A.O. to put the assessee to notice as regards the default for which penalty under Sec. 271(1)(c) was sought to be imposed.

Interest disallowance not justified if commercial expediency exists in giving interest free advances

April 5, 2025 1116 Views 0 comment Print

ITAT Mumbai held that disallowance of interest expenditure attributable to interest-free advances not justified since sufficient interest free funds available and also there existed commercial expediency in giving interest free advances. Accordingly, appeal of revenue dismissed.

ITAT Bangalore deletes Section 69 additions citing presumptive Section 44AD taxation

April 5, 2025 11328 Views 0 comment Print

ITAT Bangalore deletes additions under Section 69 citing presumptive taxation under Section 44AD and lack of supporting evidence by the AO.

Arbitrary Addition based on mobile images without corroborative evidence unjustified

April 5, 2025 5541 Views 0 comment Print

ITAT Chandigarh deleted additions made by AO for alleged undisclosed land investment based on uncorroborated mobile images in Harvinder Kaur case.

ITAT Surat Deletes Section 271(1)(c) Penalty on Estimated Purchase Addition

April 5, 2025 4161 Views 0 comment Print

ITAT Surat rules penalty under Section 271(1)(c) not sustainable where income addition is based on estimation of bogus purchases.

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