Tag: ITAT Delhi

Every provision invoked casts a different sort of onus on the assessee – ITAT deleted addition u/s 69 towards bogus purchases – ITAT In a recent judgment, ITAT Delhi has held that every provision invoked casts a different sort of onus on the assessee and assertion that merely …

When AO invoked provisions of section 37(1) to disallow purchases, provisions of section 69C of the Act are not applicable In a recent judgment, ITAT Delhi has held that when AO did not raise any doubts about the source of such purchases but invoked the provisions of section …

Wherever assessee had purchased the materials by way of E-way bill such purchases cannot be treated as bogus or non genuine – ITAT In a recent judgment, ITAT Delhi has held that wherever the assessee had purchased the materials by way of E-way bill such purchases cannot be …

Recording consolidated satisfaction note for various assessment years is fatal to the very assumption of jurisdiction under section 153C – ITAT In a recent judgment, ITAT Delhi has held that recording consolidated satisfaction note for various assessment years instead of recording independent and individual satisfaction note for each …

Assessee could not said to indulged in penny stock sale on human probabilities without showing his involvement – ITAT deleted addition under section 68 In a recent judgment ITAT Delhi deleted addition observing that applied the concept of Human probabilities and held the above said scrips to be …

AO was clearly arbitrary so as to reopen assessment against the assessee on a wrong finding of fact and conclusion thereof – ITAT In a recent judgment ITAT Delhi has held that AO was clearly arbitrary so as to reopen assessment against the assessee on a wrong finding …

Approval u/s 153D has to be granted for each assessment year. A single approval granted for all AYs held as non application of independent mind. In a recent case. The ITAT Delhi quashed a single approval u/s 153D accorded in respect of 14 Assessment Years pertaining to two …

When the provisions of Section 69A are invoked burden of proof lies on the AO to establish source of unexplained money In a recent judgment, ITAT Delhi has held that settled law is that where the AO invoked the provisions of Section 69A of the Income Tax Act, …

No estimation can be made by extrapolation and multiplication for the period for which no incriminating material were found – ITAT In a recent judgment, ITAT Delhi has held that the AO is not legally empowered to make estimation for the period, where incriminating materials do not exists, …

Approval u/s 153D granted for six assessment years by a single approval letter was mechanical and bad in law – ITAT In a recent judgment, ITAT Delhi by majority judgment held that approval u/s 153D granted for six assessment years by a single approval letter was mechanical and …