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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 1566 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 2940 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 2127 Views 0 comment Print


Latest Judiciary


Bogus Purchase Addition Restricted to Profit Element: ITAT Grants Relief

Income Tax : The case examined whether compensation paid to exit prior agreements was a sham arrangement. The Tribunal ruled it was a valid bus...

April 18, 2026 42 Views 0 comment Print

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 300 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 168 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 249 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 690 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 2466 Views 0 comment Print


ITAT Chandigarh Quashes Search Assessment for Non-Compliance with New Reassessment Regime

January 19, 2026 1014 Views 0 comment Print

The issue was whether a post-search assessment could be completed under section 143(3) using third-party material. The Tribunal ruled that the special reassessment route under sections 148 and 148B was mandatory. 

Escapement Below ₹50 Lakh: ITAT Ahmedabad Holds Reopening Beyond 3 Years Invalid

January 19, 2026 606 Views 0 comment Print

The Tribunal held that reassessment beyond three years is invalid where the alleged escaped income is below ₹50 lakh. A notice issued for a ₹5 lakh donation was declared void ab initio.

Central Circle Not Exempt from Faceless Reassessment Regime: ITAT Hyderabad

January 18, 2026 900 Views 1 comment Print

The tribunal held that reassessment initiated through a jurisdictional officer instead of the mandatory faceless mechanism was invalid. Notices under Section 148 issued after 01.04.2021 must follow the faceless scheme, failing which the entire assessment collapses.

Assessments Quashed for Non-Supply of Relied-Upon Material: ITAT Indore

January 17, 2026 1011 Views 0 comment Print

The Tribunal held that assessments based on survey and requisition material are invalid when such material is not furnished to the assessee. All quantum additions were remanded for fresh adjudication after complying with principles of natural justice.

Income of Predecessor Company Cannot Be Clubbed with Successor Post-Amalgamation

January 17, 2026 573 Views 0 comment Print

The issue was whether income of a predecessor company for years before amalgamation can be reassessed in the hands of the successor. ITAT held that such clubbing is impermissible and the reassessment itself is void.

Section 153C Assessments Quashed for Consolidated Satisfaction Note

January 17, 2026 438 Views 0 comment Print

The Tribunal examined whether a single, consolidated satisfaction note for multiple assessment years meets the requirement of Section 153C. It held that such consolidated recording vitiates jurisdiction, rendering the search assessments void.

Section 153A Additions Sustained Where Incriminating Material Exists: ITAT Ahmedabad

January 17, 2026 366 Views 0 comment Print

The Tribunal upheld additions in search assessments where seized material and settled precedent supported the Revenue’s case. The ruling clarifies that group-level incriminating evidence can justify section 153A additions.

Ex-Parte 153A Orders for Six Years Set Aside for Justice

January 17, 2026 540 Views 0 comment Print

The issue was whether six years of search assessments could stand when the first appeal was dismissed ex-parte. ITAT held that denial of meaningful hearing violates natural justice and remanded the matters for fresh adjudication.

Reopening Invalid When Search Material Triggers Section 153C

January 16, 2026 993 Views 0 comment Print

The Tribunal held that when reassessment is based on material found during a third-party search, proceedings must be initiated under Section 153C and not Section 147. Reopening under Section 147 was therefore without jurisdiction and liable to be quashed.

Search Assessments Quashed Due to Defective Section 153D Approval

January 16, 2026 435 Views 0 comment Print

The Tribunal examined whether a single approval could cover multiple assessment years in search cases. It held that separate approvals are mandatory for each year. The ruling underscores strict procedural compliance under section 153D.

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