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...
Karnataka High Court held that initiation of penalty proceedings under section 271(1)(c) of the Income Tax Act without specifying the limb under which penalty proceedings has been initiated is bad-in-law. Accordingly, question is answered in favour of respondent/assessee.
Madras High Court held that assessee can raise additional ground of validity of reassessment proceedings in terms of rule 27 of the ITAT Rules. Accordingly, ITAT justified in accepting the ground that reassessment was change of opinion.
The Tribunal held that reliance on the remand report without giving the assessee a chance to rebut violated natural justice. While the jurisdiction challenge was rejected as time-barred under section 124(3), the ₹5.80 crore LTCG addition was sent back for fresh examination. The case underscores that appellate authorities must provide fair opportunity before upholding major additions.
Madras High Court held that order of attachment of immovable property is required to be lifted as recovery officer is bound to give effect to order of higher authority. Accordingly, since entire arrears is already paid as per order passed by ITAT.
The Tribunal restricted on-money profits to 15%, deleted Transfer Pricing additions, and confirmed bogus purchase disallowances. Jurisdictional objections based on CBDT pecuniary instructions were rejected. The case provides guidance on treatment of search-assessment adjustments and substantiation requirements.
ITAT held that additions based on an unsigned, unverified Excel sheet from a third party lacked evidentiary value. The reassessment was quashed as the assessee provided independent evidence disproving alleged on-money payments.
The Court held that the approval granted for multiple search assessments was issued in a consolidated, mechanical form without case-specific consideration. It noted that Section 153D requires meaningful application of mind, which was absent in the approval examined by the Tribunal. The appeals were dismissed as no substantial question of law arose.
Tribunal emphasizes requirement of notice under section 153C for assessments in block period, quashing AY 2021-22 assessment framed without jurisdiction.
ITAT partly upheld addition of Rs.27.5 lakh as unexplained cash under sections 69A and 115BBE, granting limited relief of Rs.7.5 lakh for partial savings.
ITAT Jaipur held that addition made on the basis of documents found from the third party without providing any opportunity of cross-examination is liable to be deleted on the ground of violation of principles of natural justice.
