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Section 153A

Latest Articles


Delay in Recording Satisfaction Note Under Section 153C Can Invalidate Search Proceedings

Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...

March 11, 2026 1560 Views 0 comment Print

Special vs General: Time Limit Conflict between Section 144C(13) and Section 153 of Income Tax Act, 1961

Income Tax : Courts are divided on whether the DRP-specific deadline under Section 144C(13) overrides the general assessment time bar in Sectio...

December 16, 2025 2604 Views 0 comment Print

FAQs on Compounding of Offences under Income Tax Act, 1961

Income Tax : CBDT issues new compounding guidelines simplifying process, eligibility, charges, and procedures under the Income-tax Act from Oct...

October 30, 2025 1968 Views 0 comment Print

FAQs on Prosecution provision under Income Tax Act, 1961

Income Tax : A summary of prosecution offences under Chapter XXII of the Income Tax Act (Sections 275A to 280), detailing the rigorous imprison...

October 29, 2025 6918 Views 0 comment Print

Compounding of offence under the Income-tax Act, 1961

Income Tax : CBDT's new Compounding of Offence Guidelines (2024) simplify the process but maintain strict compliance rules. Learn about eligibi...

October 17, 2025 2940 Views 0 comment Print


Latest News


Budget 2024: Block Assessment provisions for Section 132 & 132A Searches

Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...

July 23, 2024 2127 Views 0 comment Print


Latest Judiciary


Alleged Accommodation Entry Addition deleted Due to Loan Repayment Misclassification

Income Tax : The Tribunal held that loan repayment cannot be treated as unexplained cash credit under section 68. The addition was deleted as i...

April 16, 2026 279 Views 0 comment Print

Reopening Fails on Both Counts: Invalid Sec 148A Notice and Time-Barred Sec 148 Render Assessment Void

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...

April 16, 2026 162 Views 0 comment Print

No reassessment beyond 3 years without proper sanction of prescribed higher authority

Income Tax : Reassessment proceedings was invalid for a notice issued beyond three years without the sanction of the prescribed higher authorit...

April 15, 2026 249 Views 0 comment Print

ITAT Rajkot: Addition Based on ‘Dump Excel Sheet’ Deleted – No Evidence, No Tax

Income Tax : The Tribunal held that unsigned excel sheets without supporting evidence cannot justify additions. It ruled that absence of corrob...

April 14, 2026 690 Views 0 comment Print

Third-Party Excel Sheets & Statements Without Corroboration Have No Evidentiary Value

Income Tax : ITAT Mumbai deletes Section 69 additions holding that third-party excel sheets and statements without corroborative evidence lack ...

April 13, 2026 207 Views 0 comment Print


Latest Notifications


Selection of Case of Search Years in ITBA Assessment module

Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...

September 12, 2019 2466 Views 0 comment Print


No Section 271(1)(c) Penalty for Income Surrendered During Survey & Already Disclosed in ROI

September 28, 2025 672 Views 0 comment Print

Jaipur ITAT dismisses Revenue’s appeals in Nath Corporation, Royal Jewellers, and Shri Jitendra Kumar Agarwal cases, deleting Rs. 3.3 crore in penalties.

Blanket Sanction Fatal: Tribunal Strike Down 153A Orders

September 27, 2025 342 Views 0 comment Print

Sanjay Garg Vs DCIT (ITAT Delhi) Assessee challenged assessments framed u/s 153A r.w.s. 143(3) on the ground that mandatory approval u/s 153D was granted mechanically without proper application of mind. AO had made an addition of Rs.50,00,000/- as unexplained money u/s 69, which was confirmed by CIT(A)-24, New Delhi vide order dated 28.02.2025. Before Tribunal, […]

Laptop Data Alone Cannot Justify Reopening u/s 148: Excel Sheets Not Books or Assets

September 25, 2025 936 Views 0 comment Print

ITAT Hyderabad rules Excel sheets from an accountant’s laptop aren’t ‘books’ or ‘assets,’ quashing reassessment notices against Exel Rubber for mechanical sanction and insufficient evidence.

ITAT Delhi Quashes Additions in Search-Based Assessments Without Incriminating Material

September 25, 2025 519 Views 0 comment Print

The ITAT Delhi has set aside tax additions made to Divya Exim Pvt. Ltd. and other assessees. The tribunal ruled that in completed assessments, additions cannot be based solely on third-party statements without corroborating incriminating material found during a search.

Section 153C Prevails Over Section 144 for persons other than searched person

September 24, 2025 591 Views 0 comment Print

The Income Tax Appellate Tribunal (ITAT) in Cochin has quashed an assessment order against Al Zarafa Travel & Manpower Consultants, ruling that the Assessing Officer’s jurisdiction was invalid.

ITAT Raipur Quashes Assessment for Mechanical Approval u/s 153D

September 24, 2025 381 Views 0 comment Print

The Income Tax Appellate Tribunal (ITAT), Raipur Bench, has quashed the assessment against Pawan Kumar Agrawal, ruling that the mandatory prior approval under Section 153D of the Income Tax Act.

No Section 147 Reopening on Third-Party Search Material: ITAT Raipur

September 23, 2025 717 Views 0 comment Print

The ITAT Raipur quashed the reopening of an assessment under Section 147, ruling that search-based cases on third-party material must be initiated under Section 153C.

Consolidated approval u/s. 153D granting in mechanical manner is void-ab-initio

September 16, 2025 648 Views 0 comment Print

ITAT Delhi held that assessment order passed on the basis of consolidated approval under section 153D of the Income Tax Act in mechanical manner without application of mind is void-ab-initio and hence assessment is liable to be quashed. Accordingly, appeals are allowed.

Granting of mechanical approval u/s. 153D without application of mind is illegal

September 15, 2025 654 Views 0 comment Print

ITAT Delhi held that assessment order u/s. 144 of the Income Tax Act is in violation of mandatory provisions of section 153D since mechanical approval is granted without application of mind. Accordingly, order is set aside.

ITAT Delhi Quashes Assessments Due to Invalid Section 153D Approval

September 14, 2025 1203 Views 0 comment Print

ITAT Delhi quashes assessments under Section 153A due to “mechanical” Section 153D approval by the Additional CIT. The tribunal emphasized that this approval is a mandatory safeguard, not a mere formality, and its lack of application of mind renders assessments void.

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