Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Jarnail Singh v. PCIT (2025) 234 TTJ 505 (Chd)(Trib)

S. 263: Commissioner-Revision of orders prejudicial to revenue-Commodity trading-Revision order was quashed and set aside-Cash deposit-No enquiry was made-Revision order was affirmed-Delay in filing of appeal was condoned. [S. 143(3),254(1)]

Rengasamy Asaithambi v. ACIT (2025) 234 TTJ 890 (Chennai)(Trib)

S. 251: Appeal-Commissioner (Appeals)-Powers-Direction to AO beyond ground of appeal-Violation of natural justice-Failure to issue show cause notice-The directions of the CIT(A) are deleted. [S.69A]

Amit Kumar Gupta v. ITO (2025) 234 TTJ 293/ 171 taxmann.com 16 (SMC) ((Raipur)(Trib)

S. 251: Appeal-Commissioner (Appeals)-Powers-Jurisdiction-Valid order of transfer-Matter remanded to the file of CIT(A) to decide the issue of jurisdiction. [127 (1), 127(3), 144, 147, 148]

Anshul Anil Goel v. DCIT (2025) 234 TTJ 218 / 171 taxmann.com 382 (Pune)(Trib)

S. 206C: Collection at source-Trading-Clubbing of income-Credit must be given-AO is directed to give due credit of TDS/TCS of the minor child in the hands of the assessee-Amendment in Finance Bill, 2024 regarding credit of tax collected to be given to persons other than collectee should be held as retrospective in nature and not to detriment of assessee against a legitimate claim [S.64(IA)]

Monica Capoor v. ITO (2025) 234 TTJ 851 (Delhi)(Trib)

S. 154: Rectification of mistake-Mistake apparent from the record-Enhancement of income-Inadvertent misreporting of income in the return-Affidavit filed by the chartered accountant-The affidavit and the facts stated therein require verification; the order of the CIT(A) is set aside, and the matter is restored to the AO. [S.143(1)]

Rama Allied Products Marketing (P) Ltd v. ACIT (2025) 234 TTJ 764 (Delhi)(Trib)

S. 153A: Assessment-Search-Undisclosed income-Purchases cannot be disallowed as bogus by relying on some oral statements recorded behind the back of the assessee-No addition could be made on the basis of such documents which were not found in the control and possession of the assessee-Addition deleted.[S. 69]

Harish Jain v.ACIT (2025) 234 TTJ 597/ 122 ITR 640/ 174 taxmann.com 348 (Jaipur)(Trib)

S. 153A: Assessment-Search-Undisclosed income-Statement retracted-Two agreements relating to same property-No incriminating document is found-Addition cannot be made.[S. 132(4)]

ACIT v. Alba Industries Ltd. (2025) 234 TTJ 306 (Chennai)(Trib)

S. 153A: Assessment-Search-Seized electronic material coupled with the statement given by the accounts manager of the assessee under s. 132(4) constituted incriminating material-Objection for validity of jurisdiction was rejected-Undisclosed income-Rejection of books of account justified-Estimated the profits of the assessee @ 2.21 per cent of the turnover was affirmed-Unaccounted sale proceeds could be telescoped towards the source of unaccounted expenditure and therefore, no separate addition on this account was permissible. [S.132, 132(4)]

Kumar Suman Singh v. ACIT (2025) 234 TTJ 85 / 171 taxmann.com 801 (Pat)(Trib)

S. 153A: Assessment-Search-Valid information-Proceedings are valid-Cash credits-Gift-Grandmother-No source to substantiate the gift-Addition was affirmed-Unexplained expenditure-Household expenses-Addition was affirmed.[S.68, 69C]

Colourful Estates (P) Ltd. v DCIT (2025) 234 TTJ 1 / 247 DTR 17 (Delhi) (Trib)

S. 153A: Assessment-Search-Tribunal cannot examine the legality of the search once the warrant and Panchnama were drawn on the assesse-Incriminating material-Unabated and concluded assesments-No addition can be made without incriminating material-Dairy was found in the premises of the director-Revenue failed to establish that the contents of entries discovered from a third person with the assessee-company-No addition can be made.[S. 132, 132(4),292C]