Tag: ITAT Delhi

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 …

ITAT deleted addition for late deposit of PF and ESI contributions as CPC intimations u/s 143(1) were issued prior to the decision of the Hon’ble Supreme Court In an interesting judgment, ITAT Delhi deleted addition for late deposit of PF and ESI contributions holding that CPC intimations under …