#ITAT Jaipur

The tribunal held that a section 148 notice dated 12-April-2023 was time-barred under section 149(1)(a) because the income escaping assessment was below Rs 50 lakh, and therefore quashed the assessment disallowing the claimed deduction under 80GGC for a bogus political donation. The ruling underscores that reopening notices beyond three years are invalid when the escaped income does not exceed the Rs 50 lakh threshold.

ITAT Jaipur rules that penalties in search cases must be levied under Section 271AAB of the Income Tax Act, 1961, not Section 271(1)(c). The ruling clarifies the correct penalty framework for undisclosed income detected during search assessments, impacting taxpayers facing similar proceedings.

ITAT Jaipur set aside an unexplained money addition of Rs.10,90,100 u/s 69A after finding assessee's cash withdrawals sufficient to cover credit card payments. The ruling clarifies that correlated withdrawals can rebut Section 69A additions, impacting taxpayers facing similar assessments.

ITAT Jaipur quashed an assessment under Section 153C of the Income Tax Act, 1961, after finding the Assessing Officer failed to apply mind while recording satisfaction. The ruling underscores strict compliance with statutory prerequisites for invoking Section 153C, impacting pending and future assessments based on similar jurisdictional flaws.

ITAT Jaipur quashes Section 153C assessment for AY 2014-15, ruling seized agreement dated 2012 irrelevant as it pertained to a prior year. The ruling clarifies jurisdictional limits on incriminating material under Section 153C, impacting future assessments based on third-party searches.

The ITAT Jaipur bench quashed penalty under Section 271(1)(c) after the assessee settled quantum dispute under the Direct Tax Vivad Se Vishwas Scheme 2020, holding that Section 5 grants immunity from penalty post-scheme settlement. This ruling clarifies that penalty proceedings cannot survive once a dispute is resolved under the DTVSV Act.

ITAT Jaipur rules that unexplained cash can be fully telescoped against unrecorded sales, deleting Rs.8.67L addition, and deletes Rs.15.52L addition for cash loans based on dumb documents.

When an appellate authority deletes an addition of unexplained income under Section 69A, penalties imposed under Sections 271AAC(1) and 272A(1)(d) automatically lapse - the penalty cannot stand without its foundational tax liability. This ruling protects cooperative societies and other assessees from punitive measures rooted in nullified assessments, reinforcing that penalties are consequential, not independent, under the Income Tax Act.

The ITAT Jaipur deleted a Rs. 40.82 lakh addition for unexplained cash deposits, ruling that mere deviations in cash sales or bank deposits-even amid demonetization-are insufficient to reject duly audited books of accounts. This reinforces that tax authorities must identify specific, material defects in accounting records, not rely on speculative patterns, protecting compliant businesses from arbitrary assessments.