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 Tribunal held that issuing a Section 143(2) notice is compulsory once a return is filed under Section 148. Absence of such notice vitiates jurisdiction and nullifies the reassessment.
The issue was whether common and ritualistic approval under section 153D can sustain search assessments. ITAT held that mechanical approval without independent application of mind vitiates the entire proceedings.
The notice under section 143(2) did not conform to the CBDT-prescribed format. ITAT ruled that a defective notice strikes at jurisdiction and invalidates the assessment.
ITAT held that Section 153C cannot be invoked where the satisfaction/hand-over date is after 01.04.2021, quashing multiple assessments framed thereafter. The ruling follows the Madras High Court and reinforces Section 153C(3)’s statutory bar.
The High Court held that jewellery seized during a search cannot be retained once tax liability is fully settled under the Vivad Se Vishwas Scheme. Continued detention after issuance of Form-5 was declared illegal.
The Tribunal held that additions under Section 68 could not be sustained where no incriminating material was found during search. Documentary evidence proving the loan’s genuineness was accepted.
The High Court held that an addition for unexplained investment cannot rest solely on an unsigned and unexecuted agreement. The key takeaway is that Section 69 requires concrete evidence of actual payment, not assumptions drawn from incomplete documents.
Gujarat High Court held that reopening of assessment u/s. 147 of the Income Tax Act solely on the basis of material found by AO of searched person without satisfaction note as prescribed under section 153C is untenable in law.
The issue was whether commission income could be estimated without rejecting books of account. The Tribunal ruled that estimation without invoking section 145(3) and section 144 is impermissible.
The Tribunal held that additions for completed assessment years under section 153A are invalid when no incriminating material is found during search. Reliance on third-party documents and uncorroborated statements was held insufficient to sustain additions.
