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 ruling clarifies that once a reassessment return is accepted, earlier returns lose relevance for penalty purposes. In the absence of defects in the reassessment return, penalty cannot survive.
The Revenue treated seized cash entries as unexplained income under Section 69A. The Tribunal ruled that receipts from agricultural activities are exempt and cannot be taxed merely based on seized notings.
The Tribunal ruled that reopening beyond six years is invalid without a recorded satisfaction of undisclosed assets exceeding ₹50 lakh. The takeaway is strict compliance with the fourth proviso to section 153A is mandatory.
The Tribunal examined whether prior approval under Section 153D was granted after due application of mind. It held that mechanical and routine approval invalidates the assessment, rendering the search assessment void.
The Tribunal ruled that completion of assessment after search, despite statutory abatement, is impermissible. Jurisdiction shifts exclusively to Section 153A proceedings.
It was ruled that interest for late filing of the original return can be computed based on tax determined in search-related assessment. Timely filing after notice does not negate earlier delay.
The Tribunal examined whether execution of a development agreement alone triggers capital gains. It held that without consideration or statutory transfer of possession, no capital gains arise.
The issue was whether share capital could be added in a completed assessment without seized evidence. The Tribunal held that in an unabated year, additions are barred absent incriminating material.
Where the extent of inflated purchases cannot be quantified and is restricted to a nominal percentage, penalty provisions do not apply. The ruling reinforces the distinction between estimated additions and proven concealment.
The Tribunal held that penalty proceedings fail where notices do not clearly state whether the charge is concealment or inaccurate particulars. Vague notices violate statutory requirements, leading to deletion of penalty.
