Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Baljit Singh Bachal v. ITO (2021) 207 DTR 121 / 91 ITR 100 / 214 TTJ 220 (Chd.)(Trib.)

S. 69 : Unexplained investments-Acquisition and sale without consideration-Transferred by uncle is retransferred-Addition is held to be not justified.

ACIT v. Krishan Lal Madhok (2021) 213 TTJ 734 / 206 DTR 123 (Delhi)(Trib.)

S. 69 : Unexplained investments-Addition at rate of 4% assuming saving bank account interest rate earned on bank balances with HSBC, Geneva-Illogical to compute interest rate prevailing in India as there was no documentary evidence to support presumption of AO-Same amount taxed twice in two assessment years amounts to double taxation deleted addition. [S. 153A]

Dy. CIT v. Ganpat Singhvi (2021) 214 TTJ 137 / 91 ITR 420 / (2022) 192 ITD 567 / 207 DTR 181 (Mum.)(Trib.)

S. 69 : Unexplained investments-Bank deposit-Non-Resident-Two bank accounts in HSBC Geneva-Non-Resident-Income earned in Abu Dhabi and savings made in UAE as a non-resident-Addition cannot be made merely on the basis of information received from DIT. [S. 147]

Nitin Gupta v. ITO (2021) 91 ITR 47 (SN) / 214 TTJ 247 (SMC) (Delhi)(Trib.)

S. 68 : Cash credit-Income from undisclosed sources-Bank statement of assessee showing loan from non-resident individual-During appeal proceedings filing confirmation of lender with his passport, copy of bank account and affidavit of seller-Addition not justified.[S. 69]

Kushal Virendra Tandon v. CIT (2021) 91 ITR 610 / (2022) 215 TTJ 630 (Mum.)(Trib.)

S. 68 : Cash Credits-Gift from father-Addition is held to be not justified.

Kritiprada Fashion Pvt. Ltd. v. ITO (2021) 91 ITR 149 (Surat)(Trib.)

S. 68 : Cash credits-Share Application Money-Shares issued at premium-Identity of parties, genuineness of transactions and creditworthiness proved-Additions cannot be made merely on the basis of inferences. [S. 131(1)(d)]

Kritiprada Fashion Pvt. Ltd. v. ITO (2021) 91 ITR 149 (Surat)(Trib.)

S. 68 : Cash credits-Share Application Money-Shares issued at premium-Identity of parties, genuineness of transactions and creditworthiness proved-Additions cannot be made merely on the basis of inferences. [S. 131(1)(d)]

Brash Steels Pvt. Ltd. v. ITO (2021) 91 ITR 19 (Delhi)(Trib.)

S. 68 : Cash credits-Share application money-Notice issued to share applicants u/s 133(6) of the Act-Matter remanded. [S. 133(6)]

Brash Steels Pvt. Ltd. v. ITO (2021) 91 ITR 19 (Delhi)(Trib.)

S. 68 : Cash credits-Share application money-Notice issued to share applicants u/s 133(6) of the Act-Matter remanded. [S. 133(6)]

Dy. CIT v. Ganpat Singhvi (2021) 207 DTR 181 (Mum.)(Trib.)

S. 68 : Cash credits-Income from undisclosed sources-Non-Resident-Balance in bank accounts abroad-HSBC in Geneva-Addition as peak addition is held to be not valid [S. 5(2), 69]