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 case examined whether compensation paid to exit prior agreements was a sham arrangement. The Tribunal ruled it was a valid bus...
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 : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...
Delhi High Court rules that a Section 153C notice for AY 2010-11 was time-barred. Citing the RRJ Securities Ltd. precedent, the Court confirms the six-year block period for an “other person” must be calculated from the date documents are handed over to the AO, not the date of the original search.
ITAT Delhi held that regular assessment order passed under section 143(3) of the Income Tax Act without aid of section 153C despite satisfaction note from AO of searched person is not supportable in law. Thus, assessment framed u/s. 143(3) is void ab-initio.
Delhi High Court set aside notices in Kishore Kumar Sharma vs. ACIT, affirming that Section 153C proceedings require a jurisdictional AO to record prima facie satisfaction that incriminating material impacts each relevant assessment year.
ITAT Delhi deletes ₹11.54 crore addition on loan transactions, ruling the S. 147 reassessment invalid and confirming “suspicion is not proof” for genuine loans.
Karnataka High Court held that no incriminating material was found during the search proceedings and therefore no reassessment of income for the relevant assessment year could be made under Section 153A of the Income Tax Act. Accordingly, appeal of revenue dismissed.
ITAT Delhi quashed Balaji Metal Tech’s assessment, ruling it void due to mechanical approval, wrong section use (143(3) instead of 153C), and failure to mention DIN in the order.
ITAT Delhi quashes search assessments, ruling consolidated S. 153D approval for multiple assessees was mechanical, violating judicial mandate for independent application of mind.
Assessee argued that the order was barred by limitation because it was not served within the prescribed time. AO countered this, claiming the order was dispatched via speed post on December 30, 2017, and had thus left the office within the deadline.
Late Mahabir Prasad (through L/H Mrs. Parul Kansaria) Vs DCIT (ITAT Bangalore) ITAT Bangalore Restricts Additions in Search Assessment – Statement Alone Not Incriminating- No Addition in Concluded Years Without Incriminating Material- Unaccounted Sales – Only GP Taxable, Not Entire Turnover Bangalore ITAT dealt with additions arising out of search proceedings in the A-One Steel […]
Chhattisgarh High Court held that addition under section 68 of the Income Tax Act justifiable since the money trail establishes circulation of assessee’s own unaccounted funds through shell company. Accordingly, appeal of revenue allowed and order of ITAT set aside.
