Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...
Income Tax : Courts are divided on whether the DRP-specific deadline under Section 144C(13) overrides the general assessment time bar in Sectio...
Income Tax : CBDT issues new compounding guidelines simplifying process, eligibility, charges, and procedures under the Income-tax Act from Oct...
Income Tax : A summary of prosecution offences under Chapter XXII of the Income Tax Act (Sections 275A to 280), detailing the rigorous imprison...
Income Tax : CBDT's new Compounding of Offence Guidelines (2024) simplify the process but maintain strict compliance rules. Learn about eligibi...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : The ITAT Delhi upheld deletion of a Rs.6 crore addition under Section 68 after finding that the share sale transactions were prope...
Income Tax : Delhi ITAT held that a single consolidated satisfaction note covering multiple assessment years without identifying year-wise incr...
Income Tax : The Tribunal ruled that the Assessing Officer wrongly invoked Section 143(3) despite the case being covered under the block assess...
Income Tax : The Tribunal ruled that recording satisfaction under Section 153C is not a mechanical exercise and must clearly establish the rele...
Income Tax : The Tribunal ruled in favour of the assessee after noting that audited financials, PAN, bank statements, ITRs, confirmations, and ...
Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...
The ITAT Delhi upheld deletion of a Rs.6 crore addition under Section 68 after finding that the share sale transactions were properly documented and routed through banking channels. The Tribunal held that the Assessing Officer failed to prove that the transactions represented unaccounted income.
Delhi ITAT held that a single consolidated satisfaction note covering multiple assessment years without identifying year-wise incriminating material is invalid under Section 153C. The Tribunal consequently quashed all related assessments.
The Tribunal ruled that the Assessing Officer wrongly invoked Section 143(3) despite the case being covered under the block assessment provisions of Section 153C. ITAT reaffirmed that jurisdictional defects cannot be cured by regular scrutiny proceedings.
The Tribunal ruled that recording satisfaction under Section 153C is not a mechanical exercise and must clearly establish the relevance of seized material to the assessee’s income.
The Tribunal ruled in favour of the assessee after noting that audited financials, PAN, bank statements, ITRs, confirmations, and MCA records of lenders were furnished. The ruling reinforces that documentary evidence can successfully rebut allegations of bogus loans.
The Hyderabad ITAT held that only the actual period lost during the limitation period can be excluded under Explanation-1 to Section 153. It ruled that the assessment order passed beyond the permissible period was invalid.
The Tribunal ruled that the Revenue must establish a direct connection between seized material and the assessee’s taxable income before invoking Section 153C. Mechanical initiation of proceedings for multiple years was declared invalid.
Hyderabad ITAT held that a notice issued under Section 148 after six years from the end of AY 2015-16 was invalid. The Tribunal ruled that the amended 10-year reopening provision cannot revive already time-barred cases.
ITAT Mumbai deleted additions exceeding ₹10.57 crore made under section 56(2)(vii)(c) after finding that the Assessing Officer wrongly adopted an amended valuation approach retrospectively. The Tribunal upheld the CIT(A)’s deletion in entirety.
ITAT Bangalore held that Section 45(5A) applies prospectively and cannot govern JDAs executed before 01.04.2018. Capital gains from older development agreements must be taxed under the law applicable in the year of transfer.
