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...
ITAT examined Revenue’s protective addition based on alleged beneficial ownership of foreign accounts. It upheld deletion after noting unresolved ownership and procedural gaps, emphasizing that protective additions require clear foundational evidence.
The Tribunal found that the authorities mechanically endorsed a factually incorrect premise, resulting in an unjustified DVO reference. Such a negligible 1.71% variation could not support an unexplained-investment addition under Section 69. Due to non-application of mind throughout the process, the 153A assessment was struck down entirely.
Tribunal held that assessment was void because no notice under Section 143(2) was issued, confirming that such omission cannot be cured and invalidates entire assessment.
The Court held that the search was valid after reviewing the recorded reasons and information. It ruled that jurisdiction existed under Section 132 and that challenges to procedural aspects did not invalidate the search.
The Tribunal examined alleged bogus payments to 27 sub-contractors treated as undisclosed income. While the Assessing Officer made large additions, the assessee provided affidavits confirming genuineness. The ruling partly allowed the appeals, stressing careful verification of evidence rather than assumptions.
ITAT Delhi ruled that additions under section 153A cannot be made without incriminating material specific to the assessee. All unbooked commission additions for AYs 2012-13 to 2016-17 were deleted.
ITAT held that additions under section 153A cannot be made if no incriminating material is found at the assessee’s premises; third-party documents should be invoked via section 153C.
ITAT Jaipur clarified that penalty under section 271AAB is not mandatory and requires proper examination of evidence and explanation by the assessee before imposition. Mere surrender of income does not constitute undisclosed income.
Tribunal holds that surrendered LTCG cannot be treated as undisclosed income when fully recorded in books and supported by verifiable documents. Penalty under section 271AAB was therefore not leviable.
The Tribunal held that a cash ledger found during a third-party search could not trigger Section 153C when the assessee’s name was absent. It ruled that additions fail without a direct link to the assessee.
