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 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 : ITAT Mumbai deletes Section 69 additions holding that third-party excel sheets and statements without corroborative evidence lack ...
Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...
The ITAT Delhi held that additions under Section 153A cannot be made without incriminating material found during search and set aside assessments for AYs 2013–14 and 2014–15.
ITAT Delhi held that reassessment for AY 2010-11 was invalid since it exceeded the ten-year limitation from the search year. The notice was declared time-barred and issued without jurisdiction.
TAT Delhi held that a 153C assessment for AY 2012–13 was invalid, as the six-year block must be counted from date of satisfaction recorded by AO of non-searched person.
ITAT Delhi held that ten-year block under Section 153C must be computed from date AO of non-searched person receives seized material, not search date.
ITAT Delhi held that assessments for A.Ys 2011–12 and 2012–13 were invalid since they fell outside the ten-year block reckoned from the date of receipt of seized material. The Tribunal followed CIT v. Jasjit Singh (SC) and Ojjus Medicare (Del HC) rulings.
ITAT Delhi held that a seized document mentioning ₹18 lakh could not, without corroboration, be treated as undisclosed income of Krishna Gopal Saraf, deleting the addition.
The ITAT held that the Assessing Officer cannot discard a registered valuer’s report without referring the matter to a Departmental Valuation Officer. The AO’s addition was set aside, and the fair market value must be recomputed based on the valuer’s report.
The ITAT Delhi deleted additions made under Section 153A for unabated/completed assessment years (AYs 2013-14 to 2016-17) following a search. The ruling strictly applied the Supreme Court’s mandate in Abhisar Buildwell that additions in completed years require the finding of incriminating material during the search.
The issue was whether a large cash holding was unexplained money under Section 69A post-demonetization. The ITAT ruled in favor of the assessee, accepting that the cash originated from earlier, disclosed bank withdrawals. Key Takeaway: The burden of proof to disprove the source from prior withdrawals rests with the Department; mere suspicion isn’t enough for an addition.
ITAT Chennai upheld that immovable property transfers within family through registered settlement deeds are exempt under Section 56(2)(x). The AO’s view that such transfers were non-bona-fide was rejected.
