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 found that CIT(A) erred by linking the protective addition to another company. The assessment was remanded for correct identification of the beneficiary.
The ruling highlights that immunity under DTDRS is general to penalty proceedings. Consequently, revising penalties merely because a different section might apply is impermissible.
The Revenue sought to reopen completed assessments under section 153A without fresh incriminating evidence. The Tribunal ruled that such additions are barred, following Kabul Chawla and Abhisar Buildwell.
The Tribunal ruled that the reassessment was time-barred because limitation was wrongly computed from the search date. The key takeaway is that receipt of seized material governs jurisdiction for non-searched persons.
Madras High Court held that Settlement Commission doesn’t possess power to change the head of income and convert the undisclosed portion of income into income u/s. 699B. Further, Settlement application is bound to be rejected once Settlement Commission arrives at the conclusion that full and true disclosure is not done.
The issue was whether revision under section 263 could survive when no incriminating material was found for an unabated year. The tribunal held that without search-based evidence, the completed assessment could not be disturbed.
ITAT Pune held that disallowance of interest paid on housing loan is upheld since assessee has failed to provide documentary evidence like loan sanction letter or bank certificate. Accordingly, ground raised by assessee is dismissed.
The issue was whether LTCG could be taxed in a search assessment without incriminating evidence for the year. The Tribunal held that, absent such material, additions under section 153A are unsustainable.
The issue was whether cash found at a third party’s premises could be added in the assessee’s 153A assessment. The Tribunal held such additions invalid, ruling that proceedings must be initiated under section 153C.
The issue was reopening beyond four years after a completed scrutiny assessment. The Tribunal held the reassessment invalid as there was no finding of failure to disclose material facts, a mandatory precondition under the proviso to section 147.
