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 ITAT ruled that unexplained cash can only be assessed in the year in which it is seized. An addition made in an incorrect assessment year is legally unsustainable and must be deleted.
The dispute concerned enhancement of house property income based on an unsigned lease found during search. The Tribunal held that such a document has no evidentiary value and cannot support additions.
The Tribunal set aside an appellate order confirming a ₹1.38 crore addition after finding that it lacked merit-based reasoning. The case was remanded for fresh adjudication with a speaking order.
The Revenue argued that incriminating material justified Section 153C action against a non-searched person. ITAT held that High Court quashing of notices conclusively ends jurisdiction under Section 153C.
Payments made pursuant to allotment confer valuable property rights. Their relinquishment through an agreement to sell amounts to a statutory transfer, entitling the assessee to compute gains or losses under capital gains.
The decision clarifies that voluntary admission and taxation of income post-search does not ipso facto warrant penalty. Absence of contumacious conduct weighed against the Revenue.
The Tribunal held that search-based reassessments issued beyond six assessment years are barred by limitation. Revenue appeals were dismissed as the statutory time limits could not be extended.
Revenue failed to produce a Section 153C satisfaction note showing the date of handing over seized material. ITAT treated the notice date as the deemed search date and held AY 2012-13 beyond jurisdiction.
The issue was whether an assessment could survive when statutory notices were issued in the name of a deceased person. The Tribunal held such notices invalid and quashed the entire assessment.
The Tribunal assessed compliance with revised reassessment provisions post Finance Act, 2021. It ruled that sanction by a lower authority after three years is non-est in law, leading to quashing of the reassessment.
