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 case examined whether compensation paid to exit prior agreements was a sham arrangement. The Tribunal ruled it was a valid bus...
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 : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...
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.
The Rajasthan High Court ruled that a Section 148 notice for AY 2015-16 was valid as it fell within the ten-year limit for escaped income in search cases exceeding Rs.50 lakh.
The court ruled that settlement applications filed between 01.02.2021 and 31.03.2021 remain valid since the Finance Act, 2021 took effect only on 01.04.2021, preserving vested rights during the interregnum
ITAT Mumbai held that disallowance under Section 14A cannot exceed the exempt income, upholding judicial precedents and deleting Rs. 6.66 crore addition, emphasizing that hypothetical income cannot be taxed.
ITAT Delhi held that a single Section 153D approval for multiple assessees and years is impermissible, rendering all 153A and 153C assessments void ab initio.
The Tribunal quashed additions for bogus purchases, cash seizures, and transfer pricing adjustments, affirming the AOP’s unified management and correct taxation at the consortium level.
The Court held that a Section 148 notice issued by the Jurisdictional Assessing Officer instead of the Faceless Assessing Officer was invalid, resulting in the reassessment order being set aside.
The Court found that the return filed under Section 153A contained full disclosure submitted prior to initiation of penalty proceedings. It held that such disclosure satisfied legal requirements, leaving no basis for penalty.
The Court found that reassessment must proceed through the faceless regime and not through a jurisdictional officer. Since the notice was issued in breach of this mandate, both the notice and assessment order were quashed.
Assessments on foreign-sourced income were deleted after the ITAT confirmed the assessee’s Non-Resident status under Explanation 1(a) of Section 6(1).
