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...
The Department could not produce a single document seized from the assessee, relying only on third-party statements, which are not incriminating material. The JCIT’s same-day clearance of multiple assessments without analysis led to the assessments being quashed.
The JCIT granted approval despite receiving only draft orders and no supporting evidence, demonstrating a mechanical process. The Tribunal held that such superficial approval violates judicial standards, leading to the quashing of all assessments.
The Tribunal held that VAT input credit shown only in the balance sheet cannot be taxed as income. It upheld deletion of VAT, commission, and notional interest additions, dismissing the revenue’s appeal.
The Tribunal held that penalty under Section 271AAB could not be levied because no incriminating documents were found during the search. It ruled that mere surrender of income does not constitute undisclosed income under the statutory definition.
The Tribunal examined the validity of assessments initiated under Section 153C where the Assessing Officer recorded a single consolidated satisfaction note for multiple assessment years. Following binding precedents, the Tribunal held that consolidated satisfaction is a fatal jurisdictional error and quashed the 153C assessments entirely.
The Tribunal noted that the cash was seized in a case involving narcotics, making the assessees story of property-related pooling of funds implausible. With no credible corroboration and significant inconsistencies, the addition under section 69A was upheld. The ruling stresses that factual context can outweigh self-serving explanations.
The High Court dismissed the Revenue’s appeal, affirming that the assessee discharged the initial onus under Section 68 by proving the lender’s identity and creditworthiness via banking channels and subsequent repayment with interest. It was held that doubts regarding the lender’s own creditors are irrelevant for the assessee’s assessment prior to the 2022 amendment, provided the primary transaction is genuine.
The Tribunal held that section 69A requires unexplained money or valuables to be found; since only documents showing commission were seized, invoking section 69A was invalid. Only 20% of gross commission was allowed as taxable income.
Assessments relying on third-party search material were struck down due to non-recording of satisfaction by AOs of both the searched party and the assessee. The Tribunal confirmed that 153A applies only to searches on the assessee.
ITAT Jaipur held that addition towards unaccounted commission based on seized digital sheet without corroborative evidence is not sustainable. Accordingly, addition is deleted and said ground raised by assessee is allowed.
