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 Bombay High Court held that Section 153A cannot apply to years without incriminating material, reinforcing the principle that tax additions require concrete evidence.
Karnataka High Court held that provisions of section 153C of the Income Tax Act cannot be invoked since the petitioner was a searched person and not a non-searched person / such other person. Accordingly, the proceedings quashed.
The ITAT set aside the appellate order after finding that the appeal was dismissed without proper hearing or examination of the assessee’s case.
The case addressed whether recorded purchases of ₹4.55 crore could still be treated as unexplained income. The Tribunal held that without evidence of off-book investments, section 69 has no application.
ITAT Delhi held that Section 153C proceedings cannot proceed on mere suspicion; the AO must establish that seized material impacts the assessee’s total income. The assessments for AYs 2018-19 and 2019-20 were fully quashed.
The ITAT Delhi invalidated assessments where the AO failed to record year-wise satisfaction linking seized material to the assessee. Proper satisfaction is essential for initiating Section 153C proceedings.
PCIT invoked section 263 against an assessment under section 153C. ITAT held that without challenging statutory 153D approval, revision is unsustainable, emphasizing that 153D is a statutory safeguard.
PCIT challenged a 153C assessment under section 263. ITAT held that without annulling statutory 153D approval, revision is unsustainable, confirming 153D as a statutory safeguard.
The appellate authority dismissed the appeal ex-parte citing non-prosecution. ITAT Delhi held that mere issuance of notices does not satisfy the requirement of effective hearing. The order was quashed and the matter sent back for fresh decision.
The Tribunal found that satisfaction under Section 153C was recorded long after the search and document transfer. Applying binding judicial precedent, ITAT ruled that the assessment was barred by limitation and therefore null and void.
