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Presumptive Taxation under the Income‑tax Act, 2025 — Rationale, History, Use & Misuse, and International Comparisons
Presumptive
Taxation under the Income‑tax Act, 2025 — Rationale, History, Use & Misuse,
and International ComparisonsAbstract
This article examines presumptive taxation under the Income‑tax Act, 2025. It
is...
ITAT Allows Appeal — Addition Not Sustainable in Absence of Proper Evidence — Aries Marketers vs ITO (ITAT Allahabad)
Facts of the CaseThe assessee, M/s Aries Marketers, filed an appeal
before the Income Tax Appellate Tribunal (ITAT), Allahabad Bench, challenging
the order passed by the Commissioner of Income Tax (Appeals) for the rel...
Estimated Profit Addition Without Proper Rejection of Books u/s 145(3) Unsustainable — Rajul Tandon vs DCIT (ITAT Allahabad)
Facts of the CaseThe assessee, Mr. Rajul Tandon of Allahabad, filed
an appeal before the Income Tax Appellate Tribunal (ITAT), Allahabad Bench,
against the order of the Commissioner of Income Tax (Appeals) arising from...
Condonation of Delay in Filing Appeal — Sufficient Cause Required: ITAT Allahabad in Shesh Kumar Dubey v. DCIT
Facts of the CaseThe assessee filed appeals before the Income Tax Appellate
Tribunal against orders passed by the Commissioner of Income Tax (Appeals).
However, the appeals were filed beyond the prescribed limitation p...
Penalty Proceedings Invalid Without Proper Satisfaction in Assessment Order — ITAT Allahabad in Santosh Kumar Agrahari 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 alleging concealment of income and/or furni...
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...