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 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.
The Gujarat High Court quashed a Section 153C notice due to a 22-month delay in recording the satisfaction note, ruling it violated Supreme Court guidelines for immediate post-assessment action.
The Tribunal ruled that additions based on third-party search without giving the assessee a chance to examine evidence violated natural justice, deleting ₹2.04 Cr and ₹64.11 Lakh for AY 2018-19 & 2019-20.
The ITAT held that blank letterheads found during a search are dumb documents and cannot constitute incriminating material. Since no corroborative evidence existed, all 153A additions and penalties were invalidated, reaffirming that suspicion alone cannot sustain assessments.
ITAT Delhi held that AY 2011-12 is barred by limitation under Section 153C as the deemed search year started only when documents were received in 2021, nullifying the reassessment and related penalties.
Genuine sale was established through invoices, stock records, ledgers, bank proofs, and direct buyer confirmations, leaving no room for Section 68 additions. ITAT held that when sales are proved, no commission can be presumed under Section 69C.
The Tribunal held that notices under section 153C issued without independent satisfaction by the AO are invalid, quashing the consequent assessments for AY 2018-19 to 2020-21.
The ITAT ruled that a vague, copy-paste satisfaction note cannot confer valid jurisdiction under Section 153C. Since no specific seized documents were identified, the entire assessment was struck down.
ITAT Mumbai ruled that additions under section 68 cannot stand in an unabated year without incriminating material from a search. External reports or third-party statements were insufficient, and the full addition was deleted.
ITAT Delhi held that granting blanket 153D approval without independent examination vitiates assessments. approvals under section 153D must be individualized and carefully considered.
