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 court ruled that submitting revised returns showing higher income after a search does not wipe out earlier concealment. Crimin...
Income Tax : ITAT Delhi upheld CIT(A) s order holding that reassessment under Section 153A cannot stand without incriminating material seized f...
Income Tax : Orissa High Court held that post search operation all pending assessments/reassessments doesn’t not automatically get abated as ...
Income Tax : The Tribunal quashed the reassessment as the notice issued beyond three years failed to satisfy mandatory conditions under Section...
Income Tax : Section 69C addition of ₹1.10 crore deleted as pen drive data lacked valid 65B certificate; ITAT Hyderabad held third-party digi...
Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...
Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. Inordinate delay in recording the satisfaction note can lead to the proceedings being quashed as time-barred.
The court ruled that submitting revised returns showing higher income after a search does not wipe out earlier concealment. Criminal proceedings for wilful tax evasion and false statements remain maintainable.
ITAT Delhi upheld CIT(A) s order holding that reassessment under Section 153A cannot stand without incriminating material seized from the assessee. The Revenue’s appeal was dismissed.
Orissa High Court held that post search operation all pending assessments/reassessments doesn’t not automatically get abated as provisions of section 158BA(2) of the Income Tax Act. Matter must specifically fall within Block Assessment Scheme for abatement. However, writ dismissed as power under Article 226 not invoked.
The Tribunal quashed the reassessment as the notice issued beyond three years failed to satisfy mandatory conditions under Section 149(1)(b). It held that absence of proper jurisdictional facts and compliance rendered the reopening invalid.
Section 69C addition of ₹1.10 crore deleted as pen drive data lacked valid 65B certificate; ITAT Hyderabad held third-party digital evidence inadmissible without corroboration.
ITAT Lucknow held that additions under Section 68 in search cases cannot be made without incriminating material found during search. Penny stock LTCG additions were deleted and departmental appeals dismissed.
Gujarat High Court held that the respondent officer could not have assumed jurisdiction for reopening the assessment since there was nothing which indicate that petitioner has participated knowingly in the sham transaction. Accordingly, order is quashed and set aside.
The Court directed tax authorities to release refund under Sections 240 and 244A with interest calculated up to the actual date of payment, following deletion of additions in appeal.
The Tribunal observed that the assessee discharged its burden under Section 68 by filing confirmations, financials, and banking records of the lender. In absence of contrary evidence, the onus shifted to the Revenue. The addition was rightly deleted.
