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...
ITAT Bangalore invalidated a reassessment where the assessee was not provided the recorded reasons, emphasizing that reopening notices must be supported by clear, communicated reasons before filing returns.
Madras High Court held that addition under section 68 of the Income Tax Act towards unexplained cash credit merely on the basis of certain statement without considering documentary evidence is not justifiable. Accordingly, writ of revenue is dismissed.
The issue was whether section 153C could extend beyond six years without discovery of an undisclosed asset of ₹50 lakh or more. The ITAT held that in absence of such asset-based satisfaction, extended jurisdiction is invalid.
The ITAT corrected its earlier order after noting that the liberty to reopen completed assessments under sections 147/148 was omitted. The ruling clarifies that absence of incriminating material bars search additions but not lawful reassessment.
The Revenue argued for exclusion of the 148A show-cause period to justify approval. The Tribunal rejected this, holding that the exclusion proviso applies only prospectively from Finance Act 2023.
The issue was whether a single, consolidated approval under section 153D for multiple assessees is legally valid. The ITAT held that such mechanical approval shows no application of mind and vitiates the entire search assessment.
The issue was whether penalty could survive after the underlying assessment was quashed. The ITAT held that once the 153A assessment was annulled, the penalty under section 270A automatically fell.
The Revenue invoked section 115BBE based on cash found during proceedings. However, the Tribunal found the foundational approval under section 153D defective. The entire assessment was therefore quashed.
The Tribunal held that ritualistic approval under section 153D, without application of mind, vitiates search assessments. Mandatory supervisory approval must reflect genuine examination of draft orders.
The ITAT Delhi ruled that a single approval for seven assessment years under Section 153D, issued without application of mind, is invalid, quashing the related assessment orders. The case underscores the need for careful, year-specific scrutiny.
