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 Revenue relied on alleged ₹4 crore unexplained investment to justify reopening beyond six years. The Tribunal ruled that even high-value allegations cannot override statutory limitation under section 153C.
The ITAT held that reassessment notices issued by a JAO after 29.03.2022 are void, as only a Faceless Assessing Officer can act under the faceless regime.
The ITAT ruled that reassessment under section 153C cannot extend beyond the statutory six assessment years. Jurisdiction assumed outside this period was held void.
The Tribunal reaffirmed that satisfaction must be recorded contemporaneously or immediately after the searched person’s assessment. Any belated recording invalidates the assumption of jurisdiction under section 153C.
The Tribunal held that a summary and presumptive approval under Section 153D vitiates the entire assessment. Lack of independent application of mind by the approving authority renders the assessment non-est.
Whether additions under sections 68 and 69C can be made without seized material. In search cases, completed assessments cannot be disturbed unless incriminating material is found during the search.
The issue was whether entire alleged bogus purchases should be added as income after a search assessment. The Tribunal held that where consumption and records are not disputed, only the profit element can be taxed, not the full purchase value.
ITAT Chandigarh held that passing of final assessment order under section 153A of the Income Tax Act without issuing draft assessment orders under section 144C of the Income Tax Act is untenable. Accordingly, final assessment order u/s. 153A is quashed.
The Tribunal ruled that revising Form 10 during assessment does not invalidate a trust’s accumulation claim when the original form was filed on time. The key takeaway is that revised filings before assessment completion are permissible.
The dispute concerned whether the limitation period under Section 153C should be counted from the search date or from the date seized documents were handed over. The Court held that the handover date governs, excluding earlier assessment years from reassessment.
