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 clarified that expenditure disallowances do not qualify as assets under section 149(1). Without asset-based escaped income, reopening beyond three years is barred. This offers strong protection against belated reassessments.
The Tribunal held that an assessment framed without issuing a compulsory notice under section 153C lacks jurisdiction. Even seized material cannot cure this foundational defect, rendering the order void ab initio.
The tribunal held that prior approval under Section 153D was granted mechanically without application of mind. Such invalid sanction vitiated the entire search assessment, leading to quashing of the order.
Court held that reopening of assessment based solely on vague information from Insight Portal, without a live nexus to the assessee’s records, was invalid. Reassessment notice was quashed for absence of concrete material showing income escapement.
The Tribunal held that for an unabated assessment year, additions under Section 153A must be based on incriminating material found during search. Since no such material linked to the loan was found, the Section 68 addition was deleted.
Holding that justice requires a reasoned order after hearing both sides, the Tribunal remanded the appeals. Continued non-cooperation may still permit ex parte disposal.
The decision reiterates that section 150 is subject to section 150(2) and cannot revive time-barred or jurisdictionally invalid assessments. Directions to reopen were struck down as unlawful.
The assessment relied on investigation reports without examining the alleged entry provider. The Tribunal held that cross-verification is essential before sustaining additions under section 68.
The Tribunal held that completed assessments cannot be disturbed under section 153C without incriminating material found during search. Additions based solely on third-party data were ruled invalid.
The Tribunal held that issuing a Section 143(2) notice is compulsory once a return is filed under Section 148. Absence of such notice vitiates jurisdiction and nullifies the reassessment.
