Income Tax : This document provides a complete reference on compounding of offences, including application procedures, offence-wise charges, re...
Income Tax : The FAQs explain the revised CBDT guidelines on compounding offences under the Income-tax Act effective from 17 October 2024. They...
Income Tax : The FAQs explain the prosecution provisions under the Income-tax Act, covering offences such as tax evasion, non-payment of TDS/TC...
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 : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : ITAT Delhi quashed a Section 153C assessment, holding that a consolidated and defective satisfaction note invalidated jurisdiction...
Income Tax : ITAT held that a registered sale deed without corroborative evidence is not incriminating material and cannot support additions in...
Income Tax : ITAT held reassessment under Sections 147/148 invalid because it was based on a pre-1 April 2021 third-party search, requiring pro...
Income Tax : ITAT Mumbai quashed a Section 148 notice issued after the limitation under the first proviso to Section 149, holding the reassessm...
Income Tax : ITAT held that penalty under Section 271D cannot survive where the Assessing Officer failed to record satisfaction in the assessme...
Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...
JCIT Vs. Surya Vinayak Industries Ltd. (ITAT Delhi) In the above group cases search was conducted and assessments were framed u/s 153A/143 (3). The search was conducted on 21.03.2007 and concluded on 22.03.2007. Hence last of the authorisation of search u/s 132 was executed on 22.03.2007.
ITAT-Ahmedabad In the case of M/s Shiv Associates v DCIT quashed the notice u/s 153C relying on the Judgment of the similar case related to the assessee in which the notices u/s 153C were quashed as no satisfaction was recorded by the AO.
Shri Govind G. Sarawagi HUF Vs. ACIT (ITAT Ahmedabad)- Name of the HUF, who is separate taxable entity, is no where available in the Panchnama. It is also pertinent to note that all the members of the HUF were not covered under the search action.
a person other than the person referred to in section 153A, then, the books of account or documents or assets, seized or requisitioned shall be handed over to the Assessing Officer having jurisdiction over such other person ] and that Assessing Officer shall proceed against
Pepsico India Holdings Private Ltd vs. ACIT (Delhi High Court)-Possession of documents and possession of photocopies of documents are two separate things. While the Jai puria Group may be the owner of the photocopies of the documents it is quite possible that the originals may be owned by some other person.
ITAT Pune held in Mrs Sarita Manjeet Singh Chopra Vs ITO that if the assesse had disclosed its unaccounted income filing return u/s 153A only after it was caught in search by the income tax department then that disclosed income through return would be considered as undisclosed income
ACIT Vs. S.P.Cold Storage (ITAT Raipur)- Mere mentioning of name in Search Warrant & Panchanama not sufficient for contemplating search against the assessee firm, Search at the residential premises of the Partners could not be deemed to be a search on the assessee firm
The ld. Authorised Representative for assessee submitted that the Commissioner of Income Tax (Appeals) erred in not noting that the impugned assessment had been passed in the absence of proper and valid authorization.
In an appeal no.523/2013, the assessee was engaged in the operation of a Container Freight Station (CFS). It filed a return of income on 08.10.2008 declaring total income at Rs. Nil after claiming deduction of Rs.210713675/- u/s 80IA(4) of the Income Tax Act,1961
In the case of Ms. Meena Rani Vs. ACIT, It was held by ITAT Delhi that If no satisfaction note has been recorded in the records of the searched persons but in the records of the assessee, assessment cannot be done U/s 153C
