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Invalidity of Assessment u/s 153A Based on Survey u/s 133A Without Search u/s 132 — Deletion of Additions on Stock Discrepancy, Loose Papers & Alleged Unaccounted Sales | Balaji Agricultural Industries Pvt. Ltd. v. DCIT (ITAT Allahabad)
Facts of the CaseThe assessee company was engaged in the manufacturing and sale
of agricultural equipment such as chaff cutters, Osai fans, cane crushers, and
threshers. A survey under Section 133A was conducted on 27....
Penalty under Section 271(1)(c) Unsustainable Without Proper Satisfaction and Specific Charge — ITAT Allahabad in Lal Mani Misra v. ITO
Facts of the CaseThe assessee was subjected to penalty proceedings under
Section 271(1)(c) following additions made during assessment. The Assessing
Officer initiated penalty for alleged concealment of income or furnis...
Validity of Assessment under Vivad se Vishwas Scheme — ITAT Decision in Afzal Khan v. ITO on Disputed Tax Settlement and Appeal Consequences
Facts of the CaseThe assessee had a pending income-tax dispute under appellate
proceedings. During the pendency of the appeal, the assessee opted for
settlement under the Direct Tax Vivad se Vishwas Act, 2020, which wa...
Vijaya Bank vs. JCIT (ITAT) — Allowability of Bad Debts Written Off and Provision for Doubtful Debts under Sections 36(1)(vii), 36(1)(viia) & 36(2) of the Income-tax Act, 1961
Facts of the CaseThe assessee, Vijaya Bank, a banking company, claimed deduction in
respect of bad debts written off and provisions for bad and doubtful debts in
its return of income. The Assessing Officer disallowed t...
Raj Kumar Bajpai vs. ITO (ITAT) — Validity of Addition on Unexplained Income and Evidentiary Burden under Sections 68 / 69 of the Income-tax Act, 1961
Facts of the CaseThe assessee, Raj Kumar Bajpai, was subjected to scrutiny
assessment during which certain credits, deposits, or investments were noticed
by the Assessing Officer. The assessee was required to explain t...
Ravindra Nath Singh vs. ITO (ITAT Allahabad) — Addition on Unexplained Cash Deposits and Burden of Proof under Sections 68 / 69A of the Income-tax Act, 1961
Facts of the CaseThe assessee, Ravindra Nath Singh, was subjected to scrutiny
assessment during which substantial cash deposits were found in bank accounts.
The Assessing Officer required the assessee to explain the na...
Rakesh Kumar Sahi vs. ITO (ITAT Allahabad) — Validity of Declaration Rejection under Vivad Se Vishwas Scheme (VSVS) and Scope of Disputed Tax Settlement
Facts of the CaseThe assessee, Rakesh Kumar Sahi, had pending income-tax disputes
arising from assessment proceedings. In order to resolve the dispute, the
assessee filed a declaration under the Direct Tax Vivad Se Vis...
S. Kumar Contractors vs. ITO (ITAT Allahabad) — Legality of Additions in Best-Judgment Assessment and Estimation of Income in Contract Business
Facts of the CaseThe assessee, S. Kumar Contractors, engaged in contract work, was
subjected to assessment proceedings in which the Assessing Officer rejected the
books of account and completed the assessment on a best...
Baldeo Prasad vs. ITO (ITAT Allahabad) — Admissibility of Additional Grounds and Challenge to Disallowance at Tribunal Stage under Section 254 of the Income-tax Act, 1961
Facts of the CaseThe assessee, Baldeo Prasad, was subjected to assessment
proceedings wherein certain additions or disallowances were made by the
Assessing Officer. The assessee did not contest some of these issues bef...
Ex-Parte Assessment and Additions Set Aside — ITAT Allahabad Remands Case for Fresh Adjudication in Rajendra Kumar v. ITO (ITA Nos. 120 & 121/Alld)
Facts of the CaseThe assessee was subjected to assessment proceedings for the
relevant assessment years. Due to alleged non-compliance with statutory
notices, the Assessing Officer completed the assessments ex-parte un...