Can a PCIT introduce new issues in a Section 263 order without mentioning them in the Show Cause Notice? 

1. Issue  The central issue before the Income Tax Appellate Tribunal (ITAT), Delhi Bench ‘B’, was whether the Principal Commissioner of Income Tax (PCIT) validly exercised revisionary jurisdiction under Section 263 of...

Can “Diary Notings” and “Retracted Statements” Alone Sustain an Addition? 

In appellate tax practice, the truth is simple: a case is only as strong as the evidence that supports it.  In a recent landmark decision, the Income...

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Can Profit Be Taxed Twice on the Same Bogus Purchase? 

When books of accounts are accepted, can the Assessing Officer still tax “profit” on alleged bogus purchases again?  In a recent decision, the ITAT Delhi...

Whether the delay of 304 days in filing the appeal deserved to be condoned in absence of any explanation or affidavit ? 

In the complex world of appellate tax litigation, time isn’t just a procedural formality it’s often the deciding factor between justice and finality.  The Income...

The Aishwarya Rai Bachchan ₹4 Crore Tax Case – Expert Analysis

In 2025, the Income Tax Appellate Tribunal (ITAT), Mumbai Bench, delivered a significant judgment in favor of Ms. Aishwarya Rai Bachchan, setting aside an...

Share sale proceeds not unexplained Karnataka HC upholds ITAT Order deleting Addition of Rs. 7cr. u/s 68.

Facts of the case The assessee filed its return of income, declaring a STCL on sale of shares held in X Ltd. to three entities. The...

Bought property cheaper than stamp value? That’s not ‘underreporting’.

Facts of the Case The assessee, as b co-owner, purchased two properties at consideration amounts lower than the SDV of those properties. The AO invoked section...

ITAT Judgement: You can’t call the purchases fake when you’ve already cashed in on the sales.

Facts of the case The assessee was a proprietor engaged in wholesale trading. During scrutiny, AO noticed sundry creditors of significant amount. Notices u/s 133(6) were...

Vodafone Idea Sale & Leaseback: Tax Planning or Colourable Device?

Issue Involved Whether sale and lease back transaction are permissible as a part of tax planning? Facts of the Case The assessee had claimed lease rent as...

Reassessments Need Solid Reasons and Not Just Assumptions

One of the most contested issues in tax law is the power of the Assessing Officer (AO) to reopen assessments. Sections 147 and 148...

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