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...
ITAT held that penalty under Section 271(1)(c) cannot survive where tax is ultimately levied under Section 115JB. Additions under normal provisions did not result in tax evasion.
The Tribunal ruled that long-term capital gains treated as bogus could not be added in a completed assessment year absent search-based incriminating evidence. Investigation reports alone were held insufficient.
ITAT Mumbai quashed 143(3) order post-search, deleted ₹96.77L suppressed sales addition, allowed Sec 37(1) expenses & CWIP write-off as revenue in 153A assessment.
The Tribunal held that in completed assessments, no addition can be made under Section 153A without incriminating material found during search. The addition under Section 68 was annulled as jurisdiction was invalid.
ITAT Mumbai held temporary alternate flat under development deal is not a “transfer” u/s 2(47); notarised agreement gave no ownership, so ₹13.56 lakh addition deleted.
ITAT Bangalore quashed reassessment for AY 2017-18, holding notice issued on 12-04-2024 time-barred under first proviso to Sec.149(1), despite prior 148A proceedings.
The Tribunal held that reassessment under Sections 147/148 is invalid when the assessment year is the year of search. Such cases must proceed under normal assessment provisions.
The Tribunal emphasized that assumptions based on common names cannot justify major tax additions. Without documentary linkage or banking trail confirmation, the Revenue’s case could not stand.
Penalty imposed under Section 271AAA was set aside, holding that only the Assessing Officer is empowered to levy such penalty. The Tribunal further ruled that once quantum addition is deleted, penalty cannot survive.
ITAT held that the Assessing Officer failed to record proper satisfaction linking seized material to the assessee’s income. Consequently, proceedings under Section 153C were quashed.
