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 Tribunal examined whether reassessment proceedings were valid when initiated beyond the statutory time limit. It held that the notice issued under Section 148 was barred by limitation and invalid. The ruling emphasizes strict adherence to limitation provisions in reassessment cases.
The Tribunal held that commission income cannot be computed on internal or circular banking transactions. It reduced the commission rate from 1.75% to 0.47% and directed recomputation after verification. The ruling emphasizes accurate determination of real in-come.
ITAT Delhi held that additions under Section 153A cannot be sustained without incriminating material discovered during a search, leading to deletion of major additions and dismissal of Revenue appeals.
The Delhi High Court upheld the ITAT’s decision annulling the assessment after finding that statutory approval under Section 153D was granted without proper application of mind.
The Delhi High Court upheld the ITAT s ruling that assessment orders were invalid because the approving authority granted Section 153D approval mechanically without examining the records.
The Tribunal held that entire bank deposits cannot automatically be treated as unexplained income under Section 69A. Instead, where deposits relate to commission-based transactions, only a reasonable profit percentage (2% of deposits) should be taxed.
The ITAT Chennai held that additions under Section 153A cannot be made for completed assessments when no incriminating material is found during search. Additions based only on special audit findings were therefore quashed.
Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. Inordinate delay in recording the satisfaction note can lead to the proceedings being quashed as time-barred.
The court ruled that submitting revised returns showing higher income after a search does not wipe out earlier concealment. Criminal proceedings for wilful tax evasion and false statements remain maintainable.
ITAT Delhi upheld CIT(A) s order holding that reassessment under Section 153A cannot stand without incriminating material seized from the assessee. The Revenue’s appeal was dismissed.
