Tag Archives: IN THE ITAT LUCKNOW BENCH

Consolidated Satisfaction Note Covering Multiple Years Invalidates Section 153C Assessment Proceedings

By | July 25, 2026
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Consolidated Satisfaction Note Covering Multiple Years Invalidates Section 153C Assessment Proceedings Issue Validity of Section 153C Assessment Proceedings Based on a Consolidated Satisfaction Note: Whether the initiation of proceedings and subsequent additions made under Section 69A (read with Section 153C) are legally valid when the Assessing Officer records a single, common satisfaction note covering multiple… Read More »

Departure in trading patterns alone during demonetization cannot justify a section 68 addition without rejecting the books of account.

By | July 9, 2026
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Departure in trading patterns alone during demonetization cannot justify a section 68 addition without rejecting the books of account. Issue Whether a sudden surge or change in trading patterns during the demonetization period can by itself justify an addition of cash deposits as unexplained cash credit under section 68 of the Income-tax Act, 1961, when… Read More »

Reassessment order is invalid as a mere change of opinion on already examined cash deposits.

By | July 4, 2026
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Reassessment order is invalid as a mere change of opinion on already examined cash deposits. Issue Whether the reassessment proceedings and subsequent addition under section 69A of the Income-tax Act, 1961 were valid when the specific issue of cash deposits had already been examined and accepted during the original assessment under section 143(3). Facts For… Read More »

Deemed Application of Income Spent on Immovable Property Does Not Require Schedule-I Disclosure under Form I-TR7

By | June 27, 2026
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Deemed Application of Income Spent on Immovable Property Does Not Require Schedule-I Disclosure under Form I-TR7 Issue Whether the addition of approximately ₹4.00 crores was sustainable under Section 11 of the Income-tax Act, 1961, when the assessing authorities disallowed a valid utilization of “deemed application” of income from the preceding year solely due to its… Read More »

Adjustments retained in a final assessment order must be adjudicated on merits during appeals.

By | June 25, 2026
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Adjustments retained in a final assessment order must be adjudicated on merits during appeals. Issue Whether the Commissioner (Appeals) is legally justified in refusing to decide the merits of a tax adjustment simply because the assessee did not file a separate appeal against the initial Section 143(1) intimation, even though that same adjustment was formally… Read More »