Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Anila Rasiklal Mehta (Mrs.) v. Dy. CIT (2021) 214 TTJ 849 / 63 CCH 491 (Mum.)(Trib.)

S. 69A : Unexplained money-Unexplained jewellery-Family members explained the source of investment-Addition is held to be not justified-Renovation of house property out of withdrawals from bank-Addition is not valid. [S. 69C, 132, 153A]

Gautam Kumar v. ACIT (2021) 91 ITR 28 (SN) (Delhi)(Trib.)

S. 69 : Unexplained investments-Failure to furnish explanation for source of funds for purchase of car-Addition is justified-Income surrendered not disclosed in the return-Addition as unexplained investment is proper-Addition on account of foreign tour expenses of minor and assessee is held to be justified. [S. 69C, 132(4)]

Parminder Kaur v. ITO (2021)91 ITR 216 (Amritsar)(Trib.)

S. 69 : Unexplained investments-Failure to explain the source of investment-Addition is confirmed-Delay in filing of appeal is condoned. [S. 254(1)]

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)]