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 Revenue treated seized cash entries as unexplained income under Section 69A. The Tribunal ruled that receipts from agricultural activities are exempt and cannot be taxed merely based on seized notings.
The Tribunal ruled that reopening beyond six years is invalid without a recorded satisfaction of undisclosed assets exceeding ₹50 lakh. The takeaway is strict compliance with the fourth proviso to section 153A is mandatory.
The Tribunal examined whether prior approval under Section 153D was granted after due application of mind. It held that mechanical and routine approval invalidates the assessment, rendering the search assessment void.
The Tribunal ruled that completion of assessment after search, despite statutory abatement, is impermissible. Jurisdiction shifts exclusively to Section 153A proceedings.
It was ruled that interest for late filing of the original return can be computed based on tax determined in search-related assessment. Timely filing after notice does not negate earlier delay.
The Tribunal examined whether execution of a development agreement alone triggers capital gains. It held that without consideration or statutory transfer of possession, no capital gains arise.
The issue was whether share capital could be added in a completed assessment without seized evidence. The Tribunal held that in an unabated year, additions are barred absent incriminating material.
Where the extent of inflated purchases cannot be quantified and is restricted to a nominal percentage, penalty provisions do not apply. The ruling reinforces the distinction between estimated additions and proven concealment.
The Tribunal held that penalty proceedings fail where notices do not clearly state whether the charge is concealment or inaccurate particulars. Vague notices violate statutory requirements, leading to deletion of penalty.
ITAT held that additions under Section 68 cannot be made for an unabated year unless incriminating material is found during search. Share premium additions based only on books and enquiries were rightly deleted.
