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...
The case involved reassessment triggered by a search conducted in 2022. The Court ruled that reopening beyond the 10-year statutory limit is not permissible.
ITAT Delhi held that granting of mandatory approval under section 153D of the Income Tax Act by Additional Commissioner of Income Tax in a mechanical manner and without due application of mind is an empty ritual. Thus, order held void-abinitio for want of valid approval u/s. 153D.
The tribunal reversed the CIT(A)’s decision for wrongly quashing assessment due to lack of notice under Section 143(2). It held that Section 263 proceedings are a continuation of original assessment.
The court held that parties cannot introduce additional evidence as a matter of right under Rule 29. The ITAT’s acceptance of Revenue-filed evidence and remand order was set aside as beyond jurisdiction.
The case addressed whether a special audit can be ordered without establishing complexity or defects in accounts. The Court examined whether mechanical invocation of Section 142(2A) without proper justification is legally sustainable.
The Court ruled that the reassessment notice was invalid as it exceeded the statutory 10-year limit under Section 153A. It clarified that the search year must be included in computing the extended limitation period.
ITAT held that reassessment without issuing notice under Section 143(2) is invalid, even if return was filed late. The ruling emphasizes that issuance of notice is mandatory and absence of it makes the assessment void.
The ITAT upheld ₹90 lakh addition as the assessee failed to establish genuineness and creditworthiness of the transaction. The ruling emphasizes the burden of proof on taxpayers in cash credit cases.
The issue was whether a single satisfaction note can cover multiple assessment years under Section 153C. The Tribunal held that absence of year-wise satisfaction renders the proceedings invalid. The key takeaway is that jurisdiction requires specific satisfaction for each year.
The issue was whether reassessment under Section 147 is valid after a search. The ITAT held it invalid, ruling that only Section 153A applies post-search, making the reassessment void.
