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 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 : ITAT Mumbai deletes Section 69 additions holding that third-party excel sheets and statements without corroborative evidence lack ...
Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...
The Tribunal held that revision under Section 263 cannot be exercised over a search assessment completed under Section 153C with proper approval under Section 153D. Unless such approval is shown to be erroneous, revisional jurisdiction does not arise.
The dispute centered on jurisdiction to assess under Section 153A. The Tribunal clarified that Kabul Chawla principles do not bar additions in abated assessments and ordered a de novo assessment.
The approving authority merely stated that records were perused without demonstrating scrutiny. The Tribunal held that mechanical sanction defeats the statutory purpose and nullifies the assessment.
Additions under section 153A were deleted as they rested only on an unowned diary without proof of authorship or corroborative evidence. The ruling reinforces that suspicion cannot substitute proof in search cases.
Revenue issued 153C notices for years far preceding the satisfaction date. Following binding judicial precedent, the tribunal ruled that such assessments were beyond the ten-year statutory window and could not survive.
The Tribunal held that reassessment under section 147 fails when seized search material exists. The correct and exclusive route is section 153C, making the reopening jurisdictionally invalid.
The Tribunal held that an assessment under section 153C cannot go beyond the material specified in the satisfaction note. Since additions were based on different material, the entire assessment was quashed.
The Tribunal held that reassessment initiated after three years was void because approval was taken from an incompetent authority. The key takeaway is strict compliance with section 151(ii) is mandatory and jurisdictional.
The Revenue relied on alleged ₹4 crore unexplained investment to justify reopening beyond six years. The Tribunal ruled that even high-value allegations cannot override statutory limitation under section 153C.
The ITAT held that reassessment notices issued by a JAO after 29.03.2022 are void, as only a Faceless Assessing Officer can act under the faceless regime.
