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Section 153A

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Delay in Recording Satisfaction Note Under Section 153C Can Invalidate Search Proceedings

Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...

March 11, 2026 1566 Views 0 comment Print

Special vs General: Time Limit Conflict between Section 144C(13) and Section 153 of Income Tax Act, 1961

Income Tax : Courts are divided on whether the DRP-specific deadline under Section 144C(13) overrides the general assessment time bar in Sectio...

December 16, 2025 2604 Views 0 comment Print

FAQs on Compounding of Offences under Income Tax Act, 1961

Income Tax : CBDT issues new compounding guidelines simplifying process, eligibility, charges, and procedures under the Income-tax Act from Oct...

October 30, 2025 1968 Views 0 comment Print

FAQs on Prosecution provision under Income Tax Act, 1961

Income Tax : A summary of prosecution offences under Chapter XXII of the Income Tax Act (Sections 275A to 280), detailing the rigorous imprison...

October 29, 2025 6918 Views 0 comment Print

Compounding of offence under the Income-tax Act, 1961

Income Tax : CBDT's new Compounding of Offence Guidelines (2024) simplify the process but maintain strict compliance rules. Learn about eligibi...

October 17, 2025 2940 Views 0 comment Print


Latest News


Budget 2024: Block Assessment provisions for Section 132 & 132A Searches

Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...

July 23, 2024 2127 Views 0 comment Print


Latest Judiciary


Bogus Purchase Addition Restricted to Profit Element: ITAT Grants Relief

Income Tax : The case examined whether compensation paid to exit prior agreements was a sham arrangement. The Tribunal ruled it was a valid bus...

April 18, 2026 42 Views 0 comment Print

Alleged Accommodation Entry Addition deleted Due to Loan Repayment Misclassification

Income Tax : The Tribunal held that loan repayment cannot be treated as unexplained cash credit under section 68. The addition was deleted as i...

April 16, 2026 300 Views 0 comment Print

Reopening Fails on Both Counts: Invalid Sec 148A Notice and Time-Barred Sec 148 Render Assessment Void

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...

April 16, 2026 168 Views 0 comment Print

No reassessment beyond 3 years without proper sanction of prescribed higher authority

Income Tax : Reassessment proceedings was invalid for a notice issued beyond three years without the sanction of the prescribed higher authorit...

April 15, 2026 249 Views 0 comment Print

ITAT Rajkot: Addition Based on ‘Dump Excel Sheet’ Deleted – No Evidence, No Tax

Income Tax : The Tribunal held that unsigned excel sheets without supporting evidence cannot justify additions. It ruled that absence of corrob...

April 14, 2026 690 Views 0 comment Print


Latest Notifications


Selection of Case of Search Years in ITBA Assessment module

Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...

September 12, 2019 2466 Views 0 comment Print


₹3.49 Cr Addition Deleted as Demonetisation Cash Deposits Matched Recorded Sales

December 6, 2025 936 Views 0 comment Print

The Tribunal held that cash deposits were fully supported by stock records and sales invoices, proving they were genuine business receipts. It ruled that Section 68 cannot apply to recorded turnover already taxed.

Finance Broker Taxed Only on Brokerage as No Evidence of Income Found

December 5, 2025 438 Views 0 comment Print

CIT(A)’s order upheld; assessee acted as a middleman, and no evidence supported AO’s mechanical addition. Only Rs.15.42 lakh as brokerage recognized.

Search-Based Penalties Collapsed: Additions Were Only Disallowances, Not Undisclosed Income

December 5, 2025 360 Views 0 comment Print

The Tribunal ruled that Explanation 5A applies only when the assessee is found possessing undisclosed tangible assets, which was not established. Since no such assets were discovered and the additions came from routine assessments, the penalty under section 271(1)(c) could not stand. This clarifies that the deeming fiction under Explanation 5A is not automatic.

Blocking GST Electronic Credit Ledger impermissible as pre-decisional hearing and reasons to believe not granted

December 4, 2025 411 Views 0 comment Print

Karnataka High Court held that blocking of Electronic Credit Ledger invoking rule 86A of Central Goods and Services Tax Rules [CGST Rules] without granting pre-decisional hearing and without providing reasons to believe is impermissible. Accordingly, order is quashed.

Bogus Purchase Disallowance Limited to 6% Due to Genuine Sales

December 4, 2025 480 Views 0 comment Print

The Tribunal held that once sales are accepted and basic supporting documents exist, only the profit element in alleged bogus purchases can be taxed. It upheld a 6% GP addition and rejected the Revenue’s demand for 100% disallowance.

Prior approval u/s. 153D vitiated as granted without application of mind

December 4, 2025 318 Views 0 comment Print

Bombay High Court held that grant of approval under section 153D of the Income Tax Act cannot be merely a ritualistic formality. Thus, proceedings u/s. 153A, based on approval u/s. 153D granted without application of mind, is vitiated.

Penalty Quashed Due to Vague Show-Cause Notice

December 2, 2025 588 Views 2 comments Print

The Tribunal quashed penalties for AYs 2009-10 and 2012-13, holding that show-cause notices must clearly specify the charge under Section 271(1)(c). Vague notices violating natural justice cannot sustain penalties. This reinforces the strict requirement for specificity in penalty proceedings.

Parallel Proceedings Under Section 153A and 153C Lead to Quashed Assessments

December 2, 2025 270 Views 0 comment Print

The ITAT quashed assessments under Section 153A due to ex-parte orders, mechanical Section 153D approvals, and failure to give the assessee an opportunity to be heard, emphasizing the importance of natural justice in tax proceedings.

ITAT Rejects Retraction of Voluntarily Conceded Income Under Section 153A

December 2, 2025 264 Views 0 comment Print

The Tribunal dismissed the appeal against disallowance of cash payments in a film production and real estate business. Since the assessee voluntarily offered 20% initially and later 80% of cash expenses as income, the additions were valid. The ruling emphasizes that self-conceded income cannot be contested in later appeals.

Covid & Wrong Advice Justify Delay: ITAT Calls for De-Novo Hearing on 153A Assessment

December 1, 2025 345 Views 0 comment Print

The Tribunal condoned an 868-day delay arising from wrong professional advice and Covid-related extensions, holding that the assessee showed sufficient cause. It ruled that the 50C addition under Section 153A lacked incriminating material and directed a full de-novo review.

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