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Section 153A

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Delay in Recording Satisfaction Note Under Section 153C Can Invalidate Search Proceedings

Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...

March 11, 2026 1554 Views 0 comment Print

Special vs General: Time Limit Conflict between Section 144C(13) and Section 153 of Income Tax Act, 1961

Income Tax : Courts are divided on whether the DRP-specific deadline under Section 144C(13) overrides the general assessment time bar in Sectio...

December 16, 2025 2604 Views 0 comment Print

FAQs on Compounding of Offences under Income Tax Act, 1961

Income Tax : CBDT issues new compounding guidelines simplifying process, eligibility, charges, and procedures under the Income-tax Act from Oct...

October 30, 2025 1968 Views 0 comment Print

FAQs on Prosecution provision under Income Tax Act, 1961

Income Tax : A summary of prosecution offences under Chapter XXII of the Income Tax Act (Sections 275A to 280), detailing the rigorous imprison...

October 29, 2025 6918 Views 0 comment Print

Compounding of offence under the Income-tax Act, 1961

Income Tax : CBDT's new Compounding of Offence Guidelines (2024) simplify the process but maintain strict compliance rules. Learn about eligibi...

October 17, 2025 2937 Views 0 comment Print


Latest News


Budget 2024: Block Assessment provisions for Section 132 & 132A Searches

Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...

July 23, 2024 2124 Views 0 comment Print


Latest Judiciary


Alleged Accommodation Entry Addition deleted Due to Loan Repayment Misclassification

Income Tax : The Tribunal held that loan repayment cannot be treated as unexplained cash credit under section 68. The addition was deleted as i...

April 16, 2026 216 Views 0 comment Print

Reopening Fails on Both Counts: Invalid Sec 148A Notice and Time-Barred Sec 148 Render Assessment Void

Income Tax : The issue was whether a notice granting less than the statutory minimum time is valid. The tribunal held that giving less than 7 d...

April 16, 2026 132 Views 0 comment Print

No reassessment beyond 3 years without proper sanction of prescribed higher authority

Income Tax : Reassessment proceedings was invalid for a notice issued beyond three years without the sanction of the prescribed higher authorit...

April 15, 2026 240 Views 0 comment Print

ITAT Rajkot: Addition Based on ‘Dump Excel Sheet’ Deleted – No Evidence, No Tax

Income Tax : The Tribunal held that unsigned excel sheets without supporting evidence cannot justify additions. It ruled that absence of corrob...

April 14, 2026 663 Views 0 comment Print

Third-Party Excel Sheets & Statements Without Corroboration Have No Evidentiary Value

Income Tax : ITAT Mumbai deletes Section 69 additions holding that third-party excel sheets and statements without corroborative evidence lack ...

April 13, 2026 201 Views 0 comment Print


Latest Notifications


Selection of Case of Search Years in ITBA Assessment module

Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...

September 12, 2019 2460 Views 0 comment Print


Assessment framed on basis of mechanical approval u/s. 153D is not tenable: ITAT Patna

January 31, 2026 660 Views 0 comment Print

ITAT Patna held that consolidated approval under section 153D of the Income Tax Act granted in mechanical manner by JCIT without application of mind is invalid and hence assessment framed thereon is liable to be quashed.

Day of arrival to be excluded while computing period stayed in India: ITAT Delhi

January 31, 2026 723 Views 0 comment Print

ITAT Delhi held that day of arrival should be excluded while computing number of stayed in India. Accordingly, the status of assessee is non-resident. Thus, the appeals of the assessee is allowed.

WhatsApp chat retrieved from third party not sufficient for addition: ITAT Ahmedabad

January 30, 2026 3222 Views 0 comment Print

ITAT Ahmedabad held that addition made on the basis of third-party WhatsApp chat without any incriminating material is unsustainable in law. Accordingly, order of CIT(A) upheld and appeal of revenue is dismissed.

Search Assessments Quashed for Lack of Prior U/s 153D Approval

January 30, 2026 831 Views 0 comment Print

Emphasising strict compliance, the Tribunal ruled that assessments under section 153A without prior section 153D approval are invalid. Cross-objections became infructuous once Revenue appeals were dismissed.

Income Tax Appeals Dismissed Due to NCLT Moratorium Against Personal Guarantors

January 30, 2026 294 Views 0 comment Print

This case addressed whether tax appeals survive a moratorium under insolvency law. The ruling confirms that income tax proceedings stand stayed once a moratorium is imposed.

Investor Funds of Company Cannot Be Taxed as Director’s Personal Unexplained Money u/s 69A

January 30, 2026 321 Views 0 comment Print

The Tribunal deleted both substantive and protective additions made across multiple years on the same alleged receipts. It held that such duplication results in impermissible multiple taxation of identical amounts.

Income Tax Search Assessment Quashed as 60-Day Limitation Applied After Stay Was Vacated

January 29, 2026 453 Views 0 comment Print

The issue was whether a search-based assessment could be completed within 12 months after a Supreme Court ruling. The Court held that only the 60-day extended period under section 153B applied, rendering the assessment time-barred.

Mechanical Section 153D Approval Invalid: ITAT Quashes Search Assessments for Multiple Years

January 29, 2026 528 Views 0 comment Print

The Tribunal held that a common, perfunctory sanction under Section 153D is invalid. The key takeaway is that lack of independent application of mind vitiates search assessments entirely.

Section 153A Invoked for Wrong Year; Second Search Abates First – ITAT Quashes Search Assessment for AY 2020-21

January 29, 2026 366 Views 0 comment Print

The Tribunal examined whether Section 153A could be applied to the search year itself. It held that invoking Section 153A for the wrong assessment year was invalid, rendering the assessment void.

Reopening under Section 147 Invalid Where Search Material Triggers Section 153C

January 29, 2026 894 Views 0 comment Print

The Tribunal held that where reassessment is based solely on search material found during a third-party search, proceedings must be initiated under section 153C. Reopening under section 147 was held to be without jurisdiction and quashed.

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