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 Tribunal confirmed the jurisdictional validity of reassessment based on new information. However, the addition was restored to ensure compliance with principles of natural justice and Section 250(6).
ITAT Delhi held that Section 2(22)(e) cannot apply where the assessee held less than 10% shareholding in the lending company. As statutory thresholds were not met, the deemed dividend addition was largely deleted.
Applying Supreme Court precedent, the Tribunal held that no notice could be issued once the six-year period under the old regime had expired. The reassessment order was therefore annulled.
The Court held that notice under Section 148A(b) was valid despite search-related arguments. However, the assessment was set aside due to absence of proper reasoning on denial of Section 10(38) exemption for long-term capital gains.
The Court held that reassessment based solely on material seized in a third-party search must proceed under Section 153C, not Section 148. Notices issued under the general reassessment provision were set aside.
A single approval was granted for multiple years without examining seized material or draft orders. The Tribunal ruled that such omnibus approval vitiates proceedings under Sections 153A/143(3).
The Tribunal held that reopening AY 2012–13 after a post-2021 search was barred by limitation. Applying Supreme Court guidance, it ruled that older limitation periods protect concluded assessments from retrospective reopening.
Since the reassessment notice was barred by limitation, the tribunal did not examine capital gains issues on merits. The ruling confirms that jurisdictional defects override substantive tax disputes.
ITAT Bangalore held that once the genuineness of the building construction expenditure is proved, the consequential claim of depreciation on such genuine assets cannot be denied to trust since depreciation was claimed only on actual assets used for charitable purpose.
The tribunal held that amounts already disclosed and taxed as accommodated receipts cannot be taxed again under another head. Separate additions were deleted as they resulted in impermissible double taxation.
