GST

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 the Income-tax Act, 1961, when:  The PCIT travelled beyond the scope of the...

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 Tax Appellate Tribunal (ITAT), Mumbai Bench, delivered a judgment that...

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 Bench ‘C’ delivered an insightful order in the case of...

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 Tax Appellate Tribunal (ITAT), Ahmedabad Bench, recently delivered a detailed...

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 additional disallowance of approximately ₹4 crore made by the Assessing...

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 AO having doubted the genuineness of the transactions, held that...

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 56(2)(x) treating difference between the SDV and the purchase price...

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 issued to major creditors, they were either returned unserved or...

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