Assessment Orders Passed Without Proof of Valid Section 153D Mandatory Approval Are Void and Quashed Issue Whether assessment orders passed under Section 153A/143(3) can be sustained when the Revenue fails to produce tangible evidence of valid prior approval under Section 153D after the assessee specifically challenges its compliance. Facts The assessee is an individual engaged… Read More »
Assessment Remanded to Re-examine Capital Gains Documents Pertaining to Sold Immovable Properties Assessment Remanded to Re-examine Capital Gains Documents Pertaining to Sold Immovable Properties Issue Whether an assessment addition under Section 69 of the Income-tax Act, 1961 (Section 103 of the Income-tax Act, 2025) for unexplained investment/undisclosed capital gains should be restored to the Assessing… Read More »
Invocation of Section 153A Beyond Six Years Is Void Without Identifiable Asset Under Explanation 2 Invocation of Section 153A Beyond Six Years Is Void Without Identifiable Asset Under Explanation 2 Issue Whether the assumption of jurisdiction under Section 153A beyond the ordinary six-year block is legally sustainable when the seized material fails to establish that… Read More »
Notional interest, clerical reporting errors, and substantiated trade payables cannot be taxed as income. Issue Whether notional interest calculated on interest-free business advances can be brought to tax under Section 4 of the Income-tax Act in the absence of a contractual clause or evidence of actual accrual/receipt. Whether an addition to income can be made… Read More »
Write-Off of Expired Inventory and Bad Debts Allowable as Business Expenditure Based on Verified Evidence Issue Whether the write-off of expired finished goods inventory and bad debts supported by physical verification and independent accounting reports are allowable deductions under Sections 37(1) and 36 of the Income-tax Act, 1961. Facts The assessee claimed a deduction for… Read More »
Write-off of Expired Inventory and Bad Debts Supported by Evidence Is Allowable Issue Whether the write-off of expired finished goods inventory under Section 37(1) is allowable as a business expenditure when supported by physical verification and destruction norms. Whether the write-off of bad debts under Section 36 is allowable when substantiated by debtor details, sale… Read More »
Suppressed Sale Consideration Must Be Taxed As Capital Gains, Not As Unexplained Money. Issue Whether an undisclosed receipt toward a property sale, found during a third-party search, must be taxed as part of the full value of consideration under Capital Gains in the year of transfer, or if it can be treated as unexplained money… Read More »
Section 68 Addition Based On a Third-Party Slip Stood Vitiated Due To Denied Cross-Examination Section 68 Addition Based On a Third-Party Slip Stood Vitiated Due To Denied Cross-Examination Issue Whether an assessment order making an addition under Section 68 is legally sustainable when it relies entirely on a seized slip and a statement from a… Read More »
Penalty Cannot Be Sustained on Estimated Profit Additions or Unsubstantiated Loose Sheets Issue Whether a penalty for concealment of income under Section 271(1)(c) is legally sustainable when the underlying additions are based merely on an estimation of gross profit or on unsubstantiated loose sheets recovered during a tax proceeding. Facts The Additions: For the Assessment… Read More »