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 case examined whether compensation paid to exit prior agreements was a sham arrangement. The Tribunal ruled it was a valid bus...
Income Tax : The Tribunal held that loan repayment cannot be treated as unexplained cash credit under section 68. The addition was deleted as i...
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...
Income Tax : Reassessment proceedings was invalid for a notice issued beyond three years without the sanction of the prescribed higher authorit...
Income Tax : The Tribunal held that unsigned excel sheets without supporting evidence cannot justify additions. It ruled that absence of corrob...
Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...
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.
Reassessment was struck down as no satisfaction note by the searched person’s AO was shown. The ruling reiterates that limitation cannot be bypassed through procedural shortcuts.
The issue was whether additions could be made for an unabated year without any seized material. The Tribunal held that in the absence of incriminating evidence found during search, the assessment under section 153A was invalid and liable to be quashed.
Holding the assessment void ab initio due to limitation, the Tribunal quashed the revision orders. The ruling underscores that revision cannot cure a fundamentally invalid assessment.
It was ruled that granting a single, common approval for multiple assessment years violates the mandate of Section 153D. Each assessment year requires separate and conscious examination by the approving authority.
Additions based on third-party statements alleging circular trading were rejected as they did not refer to the assessee or show any cash trail. The ruling underscores that suspicion cannot replace evidence.
The Tribunal clarified that approval under section 153D is an administrative safeguard and need not contain elaborate reasoning. Allegations of mechanical approval fail without concrete evidence of non-application of mind.
The tribunal held that assessment under section 153C cannot be initiated without seized material belonging to or relating to the assessee. Third-party statements and assumptions, without incriminating evidence, were held insufficient to confer jurisdiction
The Tribunal held that additions in a search assessment cannot survive without incriminating material. Mere repetition of an annulled earlier assessment was found legally unsustainable.
The ruling clarifies that once a reassessment return is accepted, earlier returns lose relevance for penalty purposes. In the absence of defects in the reassessment return, penalty cannot survive.
