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 Court held that an assessment order passed in the name of an amalgamating, non-existent entity is void. It ruled that system glitches cannot cure a fundamental jurisdictional defect.
The Tribunal ruled that revision under Section 263 requires examination of approval granted under Section 153D. Without establishing any defect in such approval, the assessment cannot be termed erroneous. The decision limits arbitrary revision powers.
The Tribunal examined whether reassessment proceedings were valid when initiated beyond the statutory time limit. It held that the notice issued under Section 148 was barred by limitation and invalid. The ruling emphasizes strict adherence to limitation provisions in reassessment cases.
The Tribunal held that commission income cannot be computed on internal or circular banking transactions. It reduced the commission rate from 1.75% to 0.47% and directed recomputation after verification. The ruling emphasizes accurate determination of real in-come.
ITAT Delhi held that additions under Section 153A cannot be sustained without incriminating material discovered during a search, leading to deletion of major additions and dismissal of Revenue appeals.
The Delhi High Court upheld the ITAT’s decision annulling the assessment after finding that statutory approval under Section 153D was granted without proper application of mind.
The Delhi High Court upheld the ITAT s ruling that assessment orders were invalid because the approving authority granted Section 153D approval mechanically without examining the records.
The Tribunal held that entire bank deposits cannot automatically be treated as unexplained income under Section 69A. Instead, where deposits relate to commission-based transactions, only a reasonable profit percentage (2% of deposits) should be taxed.
The ITAT Chennai held that additions under Section 153A cannot be made for completed assessments when no incriminating material is found during search. Additions based only on special audit findings were therefore quashed.
Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. Inordinate delay in recording the satisfaction note can lead to the proceedings being quashed as time-barred.
